What changed on 1 July 2026.
MiCA itself is not new — the regulation has applied to crypto-asset service providers since 30 December 2024. What changed on 1 July is the end of the transitional period: the grandfathering window that let firms already operating under national regimes keep going while they pursued full authorisation. That cover is now gone. The shift is from “you have until the deadline” to “the deadline has passed,” and three consequences follow directly.
The transitional period that allowed continued operation under legacy national registrations has ended. A firm that has not obtained a CASP authorisation (or is not validly passporting one) can no longer rely on the old national basis to serve EU clients.
Providing crypto-asset services to EU users without authorisation no longer has a lawful basis. Supervision and enforcement sit with each member state’s national competent authority, so the response to continued unlicensed activity varies — but the underlying position is the same across the bloc.
The administrative penalty framework now applies without transitional cover. The headline statutory ceiling for the most serious infringements is up to €5 million or 3% of total annual turnover, alongside public warnings and orders to cease.
Only around 17% of pre-MiCA registered entities — roughly 210 of more than 1,200 — had obtained full CASP authorisation as the deadline arrived, leaving the large majority of formerly-registered firms unlicensed. ESMA stated there would be no further extension and indicated that firms without authorisation are expected to wind down their EU activity in an orderly manner. AML obligations continue to apply through any wind-down.
For a marketing or comms team, that ~83%-unlicensed figure is the headline: enforcement attention is finite, so the most visible firms — those still advertising, onboarding, or making misleading claims into a market — are the obvious first targets. Going quiet and orderly is itself a risk-reduction measure.
What it means if you’re not authorised.
“Orderly wind-down” is not a plan you start now — it describes a state regulators expect you to already be in. If you do not hold a MiCA authorisation and your application is not on a path the authority recognises, the practical picture has three parts.
Onboarding new EU clients and marketing for acquisition into markets where you are unlicensed is the single most visible — and most enforceable — thing you can do. This is a marketing-surface decision as much as a product one: a half-live funnel behind a hidden page is still soliciting.
Where you cannot serve a market lawfully, block it or exit it cleanly. Whether your licence’s passport reaches a given member state — and where it doesn’t — is the jurisdiction question; see the map below. Reverse solicitation (Art. 61) is narrow and does not extend a market kept open with EU-language ads and geo-targeting.
Because MiCA is enforced by national authorities, consequences run along a spectrum — from supervisory warnings and public alerts to fines, and at the hard end the criminal exposure some authorities (France’s AMF among the most explicit) have flagged. “Quieter so far” does not mean safe; posture can sharpen quickly now the deadline has passed.
This is general penalty and enforcement exposure, not legal advice and not a determination of any firm’s status. Confirm your firm’s position against the live ESMA register and the national competent authority in each market you serve.
What to do now — the routes from here.
NorthPoint does not file authorisations or advise on your licence — that sits with counsel and your national competent authority. What we own is the live marketing-and-comms surface, which is where most avoidable post-deadline risk is created. Three concrete moves, fastest first.
| If you are… | The immediate move | Start here |
|---|---|---|
| Unsure whether a live asset still passes A banner, landing page, email, or KOL post still running into the EU. |
Paste the copy or URL and get a verdict against the MiCA marketing rules in seconds — before it draws a finding. | Free MiCA check → |
| Shipping assets across several EU markets, repeatedly Ongoing campaigns, multiple languages, recurring releases. |
Self-serve the full MiCA, FCA, and GDPR Pro rule packs and audit every asset — including wind-down comms — before it ships. | Self-Audit Suite → |
| Facing a whole asset-set review or a market exit A licence change, a wind-down, or a high-stakes launch. |
A signed, whole-asset-set review across your EU markets against MiCA, FCA, and GDPR, delivered in five business days. | Launch Audit → |
Whichever route fits, the principle is the same: every customer-facing message — including a wind-down notice or a delisting announcement — is still a marketing communication that has to be clear, fair, and not misleading under Article 88. The bar does not drop because the deadline has passed.
The marketing traps that bite hardest after the deadline.
Announcing a wind-down to existing clients while paid ads, EU-language pages, and KOL contracts keep pulling new users from the same market.
Active acquisition while unlicensed is the most visible and most enforceable conduct there is, and it contradicts the orderly posture you are claiming. Citation: MiCA transitional provisions; Art. 88.
Telling users you are “pausing temporarily” or will “be back soon” when no re-entry is planned, to soften a permanent exit.
A misleading return claim is its own communication breach, layered on top of the licensing problem. If the exit is permanent, say so. Citation: Art. 88 (clear, fair, not misleading).
Relying on “clients came to us” to keep serving an EU market while still running EU-language ads, geo-targeting, and influencer content.
The Article 61 exemption is narrow and is destroyed by active marketing into the EU. It is a defence for genuinely inbound, one-off requests — not a way to keep a market open. Citation: MiCA Art. 61; ESMA guidance.
Related rules.
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The deadline hub: what the transitional period was, who it covered, and what the marketing surface had to do before it closed.
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The enforcement-posture map: how hard you get hit, and where — from orderly wind-down expectations to blacklisting and criminal exposure.
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The firm-level decision page: licence, cease, orderly wind-down, transfer clients, or merge — and the reverse-solicitation trap in detail.
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The jurisdiction map: where your licence’s passport reaches, and how to geo-block or withdraw from a market without a new finding.
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The “clear, fair, and not misleading” rule every message — including a wind-down notice — must still clear.
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MiCA, FCA, SEC, GDPR — the marketing rules, quoted and explained.
This page is an operator-grade status update and heuristic for marketing and communications teams, not legal advice and not a determination of any firm’s authorisation status or any authority’s enforcement intentions. The dates, the ~83%-unlicensed figure, and the €5M / 3%-of-turnover penalty ceiling are plain-English renderings of MiCA and ESMA statements at a point in time and may change as authorities act and national implementations differ. There is no “guaranteed compliance”; for your firm’s position, confirm against the live ESMA register and consult qualified counsel and the national competent authority in each client member state.