Crypto licence in Europe since 1 July 2026: one CASP authorisation, and what happened to the national regimes
A crypto licence in Europe is, since 1 July 2026, one thing: authorisation as a crypto-asset service provider, a CASP, under Article 59 of MiCA, granted by the regulator of one EU member state and good for the whole Union. The national regimes founders still search for are closed. France’s PSAN, which the AMF called DASP in English, was repealed and every remaining DASP was delisted on 2 July 2026. Cyprus announced the end of its transitional period, with a warning to the public, on 10 July 2026. Germany’s KWG crypto-custody licence survives as a national permission with no passport. Lithuania’s window closed at the end of December 2025, Malta’s on 1 July 2026.
Passporting is a notification, not a second application: the CASP tells its home regulator which states it will serve, the regulator forwards the file within 10 working days, and services may start at the latest from the 15th calendar day. A founder outside the EU holds the authorisation through an EU subsidiary; that route is on MiCA authorisation for non-EU crypto companies. On that filing Infinilex quarterbacks, EU local counsel files.
Everything below is read from the regulation and the regulators’ own dated pages on 7 November 2026; a row that rests on a page we could not open is marked secondary. Infinilex is a legal, compliance and structuring consultancy for founders across India, the UAE and the US.
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What a crypto licence in Europe means now
MiCA never says licence. Article 3(1)(15) defines a CASP as a legal person or other undertaking that provides crypto-asset services to clients on a professional basis and is allowed to do so under Article 59, and Article 59(1) bars anyone else from providing them in the Union unless it is one of the financial entities Article 59(1)(b) lists. Table 1 takes the terms founders search for and says what each is today.
| Term | What it meant | Status since 1 July 2026 | MiCA article now | Owning page on this site |
|---|---|---|---|---|
| Crypto licence in Europe | Any national permission to run a crypto business in an EU state | CASP authorisation from a home-state regulator, passported to the other states | Articles 59, 63 and 65 | This page |
| EU crypto licence | One permission for the whole single market | No EU-level licence exists. The home regulator grants; ESMA lists the grant in its interim register, whose counts and dates are tracked on the register page | Articles 59 and 65 | CASP register by member state |
| MiCA licence | Shorthand for CASP authorisation | Right in substance; the regulation says authorisation, and the AMF itself writes “MiCA license” | Article 59(1) | MiCA authorisation |
| CASP authorisation | The legal term, Article 3(1)(15) | The only route for a crypto-native business; a non-CASP may not use a name or marketing suggesting it is one (Article 59(5)) | Articles 59, 62 and 63 | CASP readiness checklist |
| VASP registration (legacy national) | Anti-money-laundering registration under national law: DNB in the Netherlands, the Central Bank of Ireland, the Banco de España register | Ended at each state’s deadline, from 30 June 2025 (Netherlands) to 1 July 2026; Spain’s register stays for information only | Article 143(3) | MiCA vs VARA |
| DASP or PSAN (France) | The AMF’s regime under the PACTE law; DASP, digital asset service provider, is its English name for PSAN | Repealed. DASPs with a MiCA licence by 1 July 2026 were delisted on grant; all others on 2 July 2026 (AMF page, 10 July 2026) | Article 143(3), the full 18 months | This page, Table 3 |
| VFA licence (Malta) | The MFSA’s licence under Malta’s VFA framework | Transition to CASP; 18 months to 1 July 2026 on ESMA’s list. The MFSA letter of 25 June 2026 could not be opened: secondary | Article 143(3) | MiCA authorisation (Malta, Austria, Lithuania) |
| Kryptoverwahrgeschäft licence (Germany, KWG) | BaFin authorisation for qualified crypto custody, section 32(1) with section 1(1a) sentence 2 no. 6 KWG | A live national authorisation with no cross-border EEA right; a European passport exists only with MiCAR CASP authorisation (BaFin, read 7 November 2026) | Article 59; Article 143(3) for the shortened German period | This page, Table 3 |
| CASP register (Cyprus, pre-MiCA) | CySEC’s national register of crypto-asset service providers | Closed to new national applications from October 2024 (press release: secondary); MiCA applications due 27 February 2026 (release of 23 December 2025: secondary); announcement of 10 July 2026 on the end of the transitional period | Articles 62 and 143(3); CySEC Form 2 of 8 January 2025 is the application | This page, Table 3 |
Sources: Regulation (EU) 2023/1114, Articles 3, 59, 62, 63, 65 and 143 (EUR-Lex); ESMA MiCA page, read 7 November 2026; AMF DASP page, 10 July 2026; BaFin custody page and CySEC MiCA index, read 7 November 2026; ESMA grandfathering list, file dated 19 May 2026. Secondary: CySEC press releases read through search snippets; the MFSA letter of 25 June 2026 sits behind a bot check and was not read.
DASP: one set of initials, one regime that no longer exists
Searches for DASP licence requirements almost always mean France. DASP, digital asset service provider, was the AMF’s English name for the PSAN regime, and the AMF’s page of 10 July 2026 closes the question: DASPs that obtained a MiCA licence by 1 July 2026 were delisted on the day of grant, and all other registered DASPs were delisted on 2 July 2026 because the PACTE framework was repealed that day. The old withdrawal procedure, ex officio where activity had not started within twelve months of registration or had ceased for at least six months, with written comments from the firm and an ACPR opinion, went with it. A firm that wants French clients now files for CASP authorisation with its home-state regulator and passports into France.
Three legal routes to serve EU clients
Article 59(1) leaves two lawful positions for providing crypto-asset services in the Union; Article 61 adds one narrow situation in which a third-country firm is in neither. The Article 63 clock and the refusal grounds are on the CASP readiness checklist; what Article 61 still permits, and the conduct that ends it, is on MiCA reverse solicitation for non-EU exchanges.
| Route | Who qualifies | What is filed | The clock | What it does not cover |
|---|---|---|---|---|
| Article 59 CASP authorisation | A legal person or other undertaking with its registered office in a member state where it provides at least part of its services, effective management in the Union and at least one director resident in the Union (Article 59(2)) | An Article 62 application to the home regulator; CySEC takes it on Form 2 | Article 63: acknowledgement, completeness check, decision; the working-day counts are on the checklist | Services not authorised; withdrawn if unused within 12 months of grant or if no services are provided for nine consecutive months (Article 64(1)) |
| Article 60 notification | Credit institutions, central securities depositories, investment firms, e-money institutions, UCITS management companies, AIFMs and market operators, the entities in Article 59(1)(b) | A notification of the Article 60(7) information to the home regulator at least 40 working days before first provision, under each of Article 60(1) to (6) | 20 working days to check completeness; a request for missing information suspends it for up to 20 working days; no start while incomplete (Article 60(8)) | Anything beyond equivalence: an investment firm adds only the crypto-asset services equivalent to its MiFID II permissions, custody read as the ancillary custody service and a trading platform as an MTF or OTF (Article 60(3)); a CSD may add custody only (Article 60(2)), an e-money institution custody and transfers of the e-money tokens it issues (Article 60(4)), a market operator a trading platform (Article 60(6)) |
| Article 61 reverse solicitation | A third-country firm whose EU client sought the service at the client’s own exclusive initiative | Nothing; an exemption per client and per service, not a permission | None | Any solicitation, promotion or advertising in the Union, by any means, defeats it, and no contractual clause or disclaimer saves it (Article 61(1)); it never allows marketing new types of crypto-assets or services to that client (Article 61(2)) |
Sources: Regulation (EU) 2023/1114, Articles 59 to 64, EUR-Lex consolidated text, read 7 November 2026; CySEC MiCA index, Form 2 dated 8 January 2025.
How one CASP authorisation passports across the EEA
Article 59(7) is the passport: an authorised CASP may provide crypto-asset services throughout the Union, through the right of establishment, including a branch, or through the freedom to provide services, with no physical presence required in a host member state. Article 65 is the mechanism. The CASP sends its home regulator the list of states it will serve, the services, the start date and its other activities; the regulator communicates that within 10 working days to the host single points of contact, ESMA and the EBA; and the CASP may begin on receipt of that communication or, at the latest, from the 15th calendar day after filing. CySEC’s version is Form 3a, dated 5 March 2025.
Three limits. The passport is only as good as the authorisation behind it, which Article 64(1) withdraws if unused within 12 months of grant or idle for nine consecutive months. It covers the services authorised. And it stops at the EEA: ESMA’s list of transitional periods carries Norway, Iceland and Liechtenstein alongside the member states, which is why the market speaks of an EEA passport, but the United Kingdom sits outside it. Whether a payments licence sits on top of CASP authorisation where the service moves an e-money token for clients, in the EU and separately in the UK, is on stablecoin payments licence in the UK and EU. Who already holds an authorisation, by home state and brand, is on the CASP register by member state.
How the transitional period worked, and how each state closed it
Article 143(3) let a provider operating lawfully under national law before 30 December 2024 continue until 1 July 2026, or until its MiCA authorisation was granted or refused, whichever came first; a member state could refuse or shorten that period where its old framework was less strict, on notice to the Commission and ESMA by 30 June 2024; and Article 143(6) allowed a simplified procedure, between 30 December 2024 and 1 July 2026, for entities authorised under national law on 30 December 2024. ESMA’s statement of 23 June 2026, as the Central Bank of Ireland reported it on 24 June, expected unauthorised CASPs to take immediate steps to wind down their EU activities in an orderly manner; BaFin said on 8 July 2026 that since 1 July only providers holding a MiCAR licence may provide crypto-asset services in the EU. What that changed for a non-EU firm is on MiCA vs VARA. Table 3 shows the date each state actually used.
| State and regulator | Old regime | Transitional end date | Position today, and the source read |
|---|---|---|---|
| France, AMF | PSAN registration and authorisation under the PACTE law, DASP in English | 1 July 2026, the full 18 months (ESMA list) | Regime repealed; MiCA-licensed DASPs delisted on grant, the rest on 2 July 2026. AMF DASP page, 10 July 2026 |
| Cyprus, CySEC | National CASP register | 1 July 2026, the full 18 months (ESMA list); MiCA applications due 27 February 2026, with a wind-down plan from any firm not applying (press release of 23 December 2025: secondary) | National applications stopped in October 2024 (press release: secondary); Circular C674 of 7 January 2025 on the Article 143(3) period; announcement of 10 July 2026 on the end of the period and warning to the public. CySEC MiCA index and announcements, read 7 November 2026 |
| Malta, MFSA | VFA licence | 1 July 2026, the full 18 months (ESMA list) | Secondary. The MFSA Dear CEO letter of 25 June 2026 on the VFA licence and the transition to CASP refers to ESMA’s wind-down statement; neither the letter nor the MFSA MiCA page could be opened on 7 November 2026, so verify with the MFSA |
| Germany, BaFin | KWG licence, including qualified crypto custody under section 32(1) with section 1(1a) sentence 2 no. 6 KWG | 31 December 2025; Germany shortened the MiCAR period (BaFin, 8 July 2026; 12 months on the ESMA list) | KWG institutions continued on their KWG licence pending the MiCAR decision, without EU passporting, via a simplified procedure built on a BaFin gap analysis (BaFin, 22 January 2025). The KWG custody authorisation remains, with no EEA right; DORA reaches KWG custody institutions from 1 January 2027 (BaFin custody page, read 7 November 2026) |
| Lithuania, Bank of Lithuania | National crypto-asset service provider regime; detail not verified, lb.lt could not be read on 7 November 2026 | 31 December 2025 (12 months on the ESMA list; the wording is from Bank of Lithuania search snippets: secondary) | Per the same snippets, providers without a MiCA licence lost the right to operate after that date. Secondary; verify on lb.lt |
| Netherlands, AFM and DNB | DNB registration of crypto service providers | 30 June 2025, six months (AFM notice of 30 December 2024; ESMA list) | AFM licence or notification required from 30 December 2024, DNB assessing the prudential requirements. AFM notice, 30 December 2024 |
| Austria, FMA | Not verified; the FMA page returned 403 on 7 November 2026 | 12 months on the ESMA list, to about 30 December 2025 | ESMA list only. ESMA cautions that some periods on its list were national expectations not yet in national law |
| Ireland, Central Bank of Ireland | VASP registration with the Central Bank | End of December 2025: 29 December 2025 under S.I. 607/2024 on the Central Bank’s MiCAR page, which elsewhere says 31 December 2025 for VASPs (12 months on the ESMA list) | The Central Bank is the designated authority for MiCAR authorisation and supervision. MiCAR page, read 7 November 2026 |
| Spain, CNMV | Banco de España register of virtual-currency providers | 1 July 2026 (CNMV portal; 18 months on the ESMA list) | Only CNMV-authorised or other EU-authorised providers may operate; the Banco de España register remains for information only from 30 December 2024. CNMV MiCA portal, read 7 November 2026 |
Sources: Regulation (EU) 2023/1114, Article 143(3) and (6); ESMA list of Article 143(3) grandfathering periods, file dated 19 May 2026; AMF, 10 July 2026; CySEC, read 7 November 2026; BaFin, 8 July 2026 and 22 January 2025; AFM, 30 December 2024; Central Bank of Ireland, read 7 November 2026, and its markets update of 24 June 2026; CNMV, read 7 November 2026. Secondary means a search snippet or ESMA’s list alone. Counts by home state, and the ESMA periods for the states not in Table 3, are on the CASP register by member state.
The path for a founder outside the EU
A Dubai, Indian or US company cannot hold the authorisation itself (Article 59(2)); the route is an EU subsidiary, set out on MiCA authorisation for non-EU crypto companies, with what it costs to stand up and how the member state is chosen. On that filing Infinilex quarterbacks, EU local counsel files.
Two checks come first. Whether MiCA reaches your product, and what your token is in MiCA’s terms, is the MiCA self-assessment. Whether the EU or Dubai is the right first market is MiCA vs VARA; the Dubai permission itself is on crypto licence in Dubai and the UAE, and all four regimes across ten activities on crypto licence requirements by country. Issuing a stablecoin is a different question from providing a service around one; that work is stablecoin issuance.
Who signs: Infinilex counsel qualified in India, the UAE and the US sign opinions for those jurisdictions; for the EU and any other jurisdiction Infinilex scopes and coordinates the local counsel who sign. On an EU filing Infinilex builds the fact record, the group structure and the India, UAE or US legs; EU local counsel, named to you before they act, file with the home regulator. Email is answered within one working day.
Frequently asked questions
Is there an EU crypto licence, and who issues it?
No EU body issues one. Since 1 July 2026 the only permission is CASP authorisation under Article 59 of MiCA, a regime that has applied since 30 December 2024, granted by the regulator of the member state where the company has its registered office: CySEC, BaFin, the Central Bank of Ireland or the CNMV, for example. Its effective management must be in the Union and one director resident there. ESMA authorises no one; it only publishes the interim MiCA register of those grants. The authorisation reaches the other member states by an Article 65 notification, not a second application.
What are the DASP licence requirements in France now?
None, because the regime is gone. DASP, digital asset service provider, was the AMF's English name for the French PSAN regime under the PACTE law. The AMF's page of 10 July 2026 records that DASPs holding a MiCA licence by 1 July 2026 were delisted on the day of grant and every other registered DASP on 2 July 2026, the national framework having been repealed that day. A firm that wants French clients applies for CASP authorisation under Article 59 with the regulator of its home member state and passports into France under Article 65.
Which licences do I need to offer crypto trading in the EU?
One: CASP authorisation from a single member state for the services you will provide, passported across the Union under Article 65 with no physical presence required in any host state. A bank, investment firm, e-money institution or other entity listed in Article 59(1)(b) files an Article 60 notification instead, at least 40 working days before it starts (Article 60(1) to (6)). A bank may notify any crypto-asset service; the others are limited to the services MiCA deems equivalent to their existing permission, an investment firm to the equivalents of its MiFID II services and an e-money institution to custody and transfers of the e-money tokens it issues. Which listed service your product is, and the capital class that follows, are on the MiCA vs VARA page and the CASP readiness checklist.
Is Germany's crypto custody licence under the KWG a crypto licence in Europe?
Only in Germany. BaFin's page on qualified crypto custody, read 7 November 2026, describes it as an authorisation under section 32(1) with section 1(1a) sentence 2 no. 6 KWG and says a European passport is available only to companies holding MiCAR CASP authorisation. Germany shortened the MiCAR transitional period to 31 December 2025 (BaFin, 8 July 2026); KWG institutions could continue on their KWG licence pending the MiCAR decision, without EU passporting, through a simplified procedure built on a BaFin gap analysis (BaFin, 22 January 2025). DORA reaches KWG crypto custody institutions from 1 January 2027. A firm that wants clients beyond Germany needs CASP authorisation and the Article 65 notification.
Does a crypto licence from one EU country work across all of Europe?
Across the EU and the EEA, yes; across Europe on the map, no. Article 59(7) lets an authorised CASP serve the whole Union by establishment or by freedom to provide services once the Article 65 notification is made: the home regulator forwards it within 10 working days and services may begin on receipt or, at the latest, from the 15th calendar day. ESMA's list of transitional periods includes Norway, Iceland and Liechtenstein, the EEA states outside the EU. The United Kingdom sits outside both; Infinilex scopes and coordinates UK counsel for a UK leg.
Is my Lithuanian, Cypriot or Dutch VASP registration still valid?
No. Article 143(3) let firms operating lawfully before 30 December 2024 continue until 1 July 2026 at the latest, or until their MiCA application was granted or refused, and let member states shorten that period. The Netherlands gave DNB-registered providers until 30 June 2025; Germany, Ireland, Lithuania and Austria took 12 months, to the end of December 2025; France, Cyprus, Malta and Spain ran to 1 July 2026. ESMA's statement of 23 June 2026 expected any CASP still unauthorised to wind down its EU activities in an orderly manner.
Serving EU clients from Dubai, India or the US?
Tell us the services you provide, where your clients are and where your directors sit. We will map which of the three routes applies, which legs Infinilex counsel sign and which EU counsel file, before you commit to a member state.
Thirty minutes with Prashant Sharma, the founder, who does the work himself. You leave with next steps either way. Email is read by the founder and answered within one working day.
Further reading
MiCA authorisation for non-EU crypto companies · The MiCA CASP readiness checklist · MiCA CASP register by member state · MiCA vs VARA · MiCA reverse solicitation for non-EU exchanges · MiCA self-assessment · Stablecoin payments licence in the UK and EU · Crypto licence requirements by country · Crypto licence in Dubai and the UAE · Stablecoin issuance
This article is general information for founders, not legal advice on your services, entity or structure. Regulation (EU) 2023/1114 was read in the EUR-Lex consolidated text and regulator pages on the dates stated, all on or before 7 November 2026. Rows marked secondary rest on a search snippet or on ESMA’s list alone and should be verified with the regulator named. Have the position reviewed before you rely on any of the above.