What is MiCA?
MiCAR is the first comprehensive regulatory framework in the European Union aimed at supervising the crypto market, including tokens, stablecoins, and service providers (CASPs).
MiCAR took shape with the goal of harmonizing how crypto-asset services are regulated across Member States. This EU-wide framework for crypto regulation aims to bring legal clarity for crypto exchanges, stablecoin issuers, and crypto-asset service providers (CASPs).
By April 2025, while many national legislators across the EU have fully or partially adopted MiCA into domestic law, several others have made little to no progress. This uneven implementation has created a mixed regulatory landscape, with some Member States already driving new compliance requirements and market opportunities, while others leave crypto businesses in uncertainty.
Key Dates
- June 30, 2024: Stablecoin rules kicked in; issuers of asset-referenced tokens and e-money tokens become subject to MiCA obligations.
- December 30, 2024: The Full MiCA framework has taken effect. Existing crypto-asset service providers (CASPs) have begun transitioning or securing their authorizations.
- By mid- to late 2025: Various Member States require local CASPs to file for MiCA authorization if they want to keep operating. Some countries, like Germany, set the end of 2025 as the cut-off for their shortened grandfathering period, meaning firms must obtain full MiCA authorization by then to continue operations. For a detailed breakdown of each country’s transitional period, you can consult the official ESMA list of MiCA grandfathering periods (PDF).
- July 1, 2026: End of the transitional period in most Member States. CASPs lacking authorization will be forced to cease crypto-related activities until they are fully compliant and authorized.
Early Adopters
Several EU jurisdictions have taken a proactive approach to implementing MiCA, providing crypto-asset businesses with early clarity on authorization, supervision, and compliance requirements for crypto exchanges and token issuers. This head start has helped them cultivate local digital asset ecosystems more rapidly than their counterparts. Below are five prime examples of Member States that moved early and decisively.
Germany
- a formal MiCA authorization decision,
- the expiration of the EU-wide deadline (June 30, 2026),
- or December 31, 2025.
Malta
- Foris Dax Mt Limited (better known as Crypto.com);
- Okcoin Europe Ltd (operating under the trade name OKX);
- Zillion Bits Ltd (ZBX platform).
Netherlands
Luxembourg
Lithuania
Estonia
Moderate Implementers
These EU countries have introduced MiCA-related legislation or updates and are broadly on schedule, though their frameworks may not be as aggressively proactive as those of the early adopters. They typically allow the full 18-month transition period or only slightly shorter windows, so businesses have a comfortable—if not entirely seamless—path to compliance. Below, we look at how the Czech Republic, Luxembourg, and Spain fit this category.
Czech Republic
Many local crypto businesses are thus waiting on further guidance from the Czech National Bank before making comprehensive compliance changes. Nevertheless, the combination of a stable financial environment and a reasonably flexible approach puts Czech providers in a decent position to adapt.
France
However, no CASPs have been authorized in France as of now.
Spain
The Comisión Nacional del Mercado de Valores (CNMV), designated as the primary supervisory authority, has published a detailed authorization manual and notification model for CASPs.
Starting from September 2024, prospective applicants were encouraged to begin submitting their documentation and to schedule pre-filing consultations to speed up processing. While no authorizations will be issued before the December 2024 go-live date, the CNMV has laid out clear technical standards and submission requirements in line with upcoming ESMA guidance.
Lagging Group
Unlike the early adopters or moderate implementers, these countries have been slow or unclear in translating MiCA’s rules into actual national frameworks. This creates significant uncertainty for local crypto businesses and potential entrants, as no well-defined paths to authorization are yet in place.
Poland
As of 2025, Poland has not introduced a national law aligning with the EU MiCA crypto regulation, leaving crypto service providers in Poland without a formal pathway for MiCA CASP authorization.
Despite some existing AML requirements for virtual currency businesses,the Polish draft of the MiCA-related law remains unadopted by the parliament of Poland.
Additionally, no competent authority like the Polish Financial Supervision Authority (KNF) has been officially appointed to oversee MiCA implementation.
Given that the legislative process in Poland typically takes at least 2–3 months, the timely implementation of MiCA into national law appears increasingly unrealistic.
As a result, both local and foreign businesses remain in regulatory limbo, unable to plan their compliance roadmap or apply for authorization under the MiCA framework, and have no clear timeline or procedure for securing a MiCA authorization. This lack of progress leaves the local industry in a holding pattern, awaiting legislative action or official guidance.Portugal
The Bank of Portugal continues to register providers under older AML-based rules, but no guidance exists on how or when existing market participants must seek MiCA authorization.
Consequently, new applicants, in particular, are stuck waiting for implementing legislation, meaning local and incoming CASPs remain in regulatory limbo.
Belgium
While MiCA is a directly applicable EU law, Belgium has yet to pass a national act appointing a competent authority (like the FSMA) to process CASP authorization. Without this, no local firm can submit a formal application, and even large financial institutions cannot use MiCA’s notification procedure for existing regulated entities.
Although EU-based CASPs from other Member States can continue serving the Belgian market under passporting rules until mid-2026, domestic providers are left without a pathway to compliance, making Belgium heavily reliant on foreign players in the short term.
Summary
MiCA has already begun reshaping the EU’s regulatory landscape for digital assets, but the pace and depth of each Member State’s implementation vary considerably. Some, like Germany, Malta, the Netherlands, Lithuania, France, and Estonia, acted swiftly and devised well-defined rules or transition pathways, allowing crypto businesses to secure authorization quickly and confidently.
The second tier—including the Czech Republic, Luxembourg, and Spain—has essentially kept to MiCA’s default timelines, enabling service providers to proceed without undue haste or complication. At the other end of the spectrum, countries such as Poland, Portugal, and Belgium still offer little clarity on precisely how MiCA will be enforced. Consequently, businesses seeking to operate there must navigate legal uncertainty while hoping for imminent policy updates.
Collectively, these varying approaches underscore why MiCA’s long-range goal—harmonizing the EU’s crypto rules—remains a work in progress.
The promise of a single, passportable authorization encountered national discrepancies and uneven enforcement in practice, which could persist for some time. Nonetheless, as the transition to MiCA continues, most market participants expect further progress in bridging these gaps and fostering a robust, unified environment for crypto innovation across Europe.
Need guidance on how MiCA affects your crypto business? Our team of regulatory experts helps navigate CASP licensing, whitepaper compliance, and cross-border operations.
Frequently Asked Questions
What is the MiCA Regulation, and when does it take full effect in the EU?
Markets in Crypto Assets, or shortly MiCA, presents a regulatory authority within the European Union that oversees the development of blockchain technology and cryptocurrencies in the region. This regulatory entity aims to enhance legal transparency and clarity among crypto exchanges, stablecoin issuers, and crypto-asset service providers (CASPs) in the member countries. It took its full effect on December 30th, 2024. It is when the MiCA extended its regulations to the CASPs.
Which EU countries have fully implemented MiCA so far?
Such countries as Germany, Malta, the Netherlands, Luxembourg, Lithuania, and Estonia have fully adopted the MiCA regulations, providing their local crypto-asset ventures with sufficient supervision, authorization, and compliance for crypto exchanges and token issuers. Their successful implementation of MiCA also provides these countries with internal controls and technical infrastructure while they operate in perfect alignment with the current EU standards.
What happens to crypto businesses in countries that haven’t implemented MiCA yet?
The list of countries that have been relatively slow in implementing MiCA regulations includes Poland, Portugal, and Belgium. As a result of their uncertain position, both local and international crypto businesses in these regions are currently unable to apply for the necessary authorization under MiCA and are heavily dependent on foreign providers for an unspecified period of time. In other words, the incoming and local CASPs are stuck in a so-called regulatory limbo.
