CSSF ·

EU ends MiCA transition for virtual asset service providers on 1 July 2026

Crypto-asset service providers serving EU customers must hold CASP authorisation or wind down EU operations, blocking onboarding, account openings and advertising

Change
On 1 July 2026 the Commission de Surveillance du Secteur Financier (CSSF) confirmed the MiCA transition period ended: virtual asset service providers must hold crypto-asset service provider (CASP) authorisation to provide crypto-asset services in the EU, and providers without authorisation must wind down EU activities and cannot onboard new customers, open accounts or wallets, or advertise.
Why it matters
Unauthorised providers are prohibited from onboarding new EU customers, opening new accounts or wallets, and advertising or distributing products inside the EU, and must limit activity to the actions necessary to allow customers to exit in an orderly manner. Third-country providers that actively solicit EU customers — through online advertising, brochures, telephone calls, emails, banners, pop-ups or social media — must obtain EU CASP authorisation. The 'reverse solicitation' exemption applies only where the customer initiates contact; providers that wrongly rely on it may be prohibited from providing services and forced to close customer accounts at short notice.
Implications
  • Crypto-asset service providers serving EU customers must hold EU CASP authorisation or wind down EU operations — absent authorisation, they cannot onboard new customers, open accounts or wallets, or advertise or distribute products, and must restrict activity to orderly customer exit.
  • Applies if you actively solicit EU customers: third-country crypto-asset service providers soliciting EU customers through online ads, brochures, telephone calls, emails, banners, pop-ups or social media must obtain EU CASP authorisation or cease soliciting and wind down EU-facing activities — the 'reverse solicitation' exemption covers only customer-initiated contact, and wrongful reliance on it can trigger a prohibition and short-notice account closures.
  • Compliance and onboarding teams at providers relying on 'reverse solicitation' must evidence that each EU customer relationship was customer-initiated — undocumented solicitation exposes the provider to a prohibition on providing services and forced account wind-down.
Who is affected
  • Crypto-asset service providers serving EU customers
  • Third-country crypto-asset service providers actively soliciting EU customers
  • Compliance and onboarding teams relying on the reverse-solicitation exemption

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