16/12/2025
MiCA Update | December 2025
MiCA has been fully applicable to Crypto-Asset Service Providers since the 30th of December 2024. While the pace of new legislative texts slowed between August and mid-November 2025, regulatory focus has clearly shifted to authorizations, supervision, and the end of transitional regimes.
As of mid-November 2025, ESMA’s CASP register shows continued growth in authorized entities, with new licenses issued mainly in Spain, Ireland, and France, alongside additional approvals in Germany and the Netherlands. Passporting is now actively used, enabling authorized CASPs to operate across multiple EU Member States.
Transitional regimes are reaching their critical phase.
In jurisdictions such as Germany, Spain, Ireland, Austria, and Greece, the transitional period expires on 31 December 2025. From 1 January 2026, entities without full CASP authorization will no longer be permitted to provide services to EU clients. Other Member States with the full 18-month window remain open until 1 July 2026, though many firms are applying early to secure passporting rights.
Poland: legislative reset, not cancellation.
On 1 December 2025, the Polish President vetoed the national law intended to implement MiCA. This veto reset the local legislative process. The Possible next steps include a new law with minimal changes, adoption of MiCA, or a softened national version, both likely pushing implementation into Q1 2026. CASP and VASP applicants should continue preparations, as the substantive MiCA requirements remain unchanged.
The coming weeks are decisive. Deadlines are firm, supervisory expectations are already being applied in practice, and late preparation carries real commercial risk.
If you operate, or plan to operate, a crypto exchange, custody service, or other CASP activity in or into the EU, now is the time to ensure your MiCA licensing strategy is solid.
As we support crypto businesses throughout the MiCA authorization process, get in touch to secure your EU market access.
