MiCAR Transitional Period for Crypto-Asset Service Providers Expires: What Luxembourg Market Participants Need to Know Now

Short summary

The 18-month MiCAR transitional period expired on 1 July 2026, meaning any entity providing crypto-asset services in Luxembourg without a valid CASP authorisation is now operating illegally. Former VASPs must obtain full MiCAR authorisation or complete notification procedures, while unauthorised CASPs are expected by ESMA to wind down EU activities in an orderly manner. Investment fund managers, depositaries, and credit institutions must urgently verify that appointed CASPs hold valid MiCAR authorisations and update service agreements and fund documentation accordingly.

• •MiCAR transitional period expired 1 July 2026; VASP registration alone is no longer a valid legal basis for crypto-asset services in Luxembourg
• •ESMA expects unauthorised CASPs to immediately stop onboarding EU clients and wind down activities while safeguarding client interests
• •IFMs, depositaries, and credit institutions must verify CASP authorisation status, revisit service agreements, and update fund documentation for MiCAR compliance

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