VASP-to-CASP Transition: The 1 July 2026 Deadline Explained

What does Article 143 actually do?

Article 143 provides the bridge from the pre-MiCA regulatory landscape to the unified MiCA regime, allowing existing VASPs to continue operating during the transition. Before 30 December 2024, crypto-asset services in the EU were regulated under a patchwork of national VASP registers — Estonia’s regime from 2017, Lithuania’s from 2020, the Czech Trade Licensing Office regime, France’s PSAN registration. Each had different substance requirements, different documentation, different supervisory tone.

MiCA replaces all of those. Article 143 provides a one-time transition mechanism so that firms operating under the old regimes do not have to cease operations during the regulatory shift. The mechanism has three components:

1. Continuity. Existing VASPs may continue to provide crypto-asset services in their member state of registration during the transitional period.
2. Filing requirement. To use the transitional regime, the firm must file a complete CASP application with the home regulator before the member-state deadline.
3. End date. When the home regulator approves or refuses the CASP application — or when the deadline passes without an application — the transitional regime ends for that firm.

The default end date is 1 July 2026 across most member states. Italy and Spain have extended their domestic deadlines to 30 December 2026 under Article 143(3). Estonia and France retain the 1 July date.

Who does Article 143 apply to?

The transitional regime applies only to firms that held an EU national VASP registration in good standing as of 30 December 2024 and were actively providing crypto-asset services on that date.

To qualify, a firm must, as of 30 December 2024:

• Held a national VASP registration or equivalent permission to provide crypto-asset services in an EU member state
• Were actively providing those services (not dormant)
• Held registration in good standing (not suspended or revoked)

Firms that registered after 30 December 2024 do not qualify. Firms that ceased operations before that date do not qualify. Firms whose registration was revoked by the home regulator do not qualify, regardless of the reason for the revocation.

The exact list of qualifying VASP regimes per member state is set out in ESMA’s Q&A on MiCA transitional provisions, last updated March 2026. Counsel should check the Q&A specifically for the target member state — there are some non-obvious exclusions, including some Czech Trade Licensing Office sub-categories that ESMA has clarified do not qualify as VASP registrations for Article 143 purposes.

Which member states have shorter or longer deadlines?

The default deadline is 1 July 2026, but Italy and Spain have extended to 30 December 2026 under Article 143(3) — most other EU member states retain the default.

While 1 July 2026 is the default deadline, member states retained discretion under Article 143(3) to set shorter or longer windows. The current state of play, as of April 2026:

Member state	Deadline	Notes
Lithuania	1 July 2026	Default deadline, Bank of Lithuania actively processing
Estonia	1 July 2026	FSA applying full substance review to transitional files
Czech Republic	1 July 2026	Transitioned from Trade Licensing Office to ČNB January 2026
Poland	1 July 2026	KNF backlog significant; expect deadline pressure
Bulgaria	1 July 2026	Default; smaller market
Cyprus	1 July 2026	CySEC integration of crypto-asset oversight ongoing
Spain	30 December 2026	Extended window under Article 143(3)
Italy	30 December 2026	Extended window; CONSOB capacity-building
France	1 July 2026	AMF maintaining default

The longer windows in Spain and Italy are a function of regulator capacity rather than a more permissive substance review. Firms that move their application to Spain or Italy purely to use the longer window typically find the substance review at least as rigorous as in the default-deadline jurisdictions.

What does the transitional dossier contain?

The transitional CASP application is the full Article 62 dossier — the same documentary set required of a brand-new entrant — with three additional disclosures specific to the existing-VASP context.

The transitional CASP application is the full Article 62 dossier. There is no abbreviated version. Counsel preparing a transitional application should treat it as a new-entrant filing with the additional complication that the firm is already operating, which raises the regulator’s interest in supervisory continuity.

The full dossier under Article 62 MiCA includes:

• Programme of operations
• Description of internal control mechanisms, risk-management framework, and AML/CFT arrangements
• ICT risk-management framework (DORA-aligned)
• Description of governance arrangements, including conflict-of-interest matrix
• Identity and fit-and-proper documentation for all directors and qualifying shareholders
• Initial-capital evidence
• Professional-indemnity insurance or additional own funds
• Description of segregation of client assets (Class 3)
• Recovery plan (Class 3)
• Marketing communications policy
• Complaints handling procedure

For transitional applicants, the regulator will additionally request:

• Existing VASP registration certificate
• Operating-history summary (typically three years)
• Material changes since registration
• Confirmation that the firm meets MiCA-aligned substance requirements

The “material changes” disclosure is important. Regulators use it to identify firms whose operating model has drifted away from the basis on which the original VASP registration was granted. Firms that have materially expanded or pivoted should expect heightened scrutiny.

When should existing VASPs file the transitional application?

File as soon as the dossier is genuinely complete — the regulatory capacity at most home regulators is already past peak, and tail-of-deadline filers face slower review cycles.

Filing immediately on 30 December 2024 (when MiCA entered into force) was mostly impossible — the implementing acts and regulator portals weren’t ready. Filing in Q1 2025 was difficult — supervisors were still building internal capacity. Filings have been ramping through 2025, with the highest volumes in Q4 2025 and Q1 2026.

The bell curve creates a capacity-pressure problem at most regulators. Files arriving in May and June 2026 will hit a different regulator than files that arrived in November 2025. The most common pattern we observe at the tail of the bell curve is:

• Slower completeness review (5-15 days vs 5 days)
• More extensive first-substantive-review information requests
• Longer iteration cycles between deficiency rounds

The implication for filing strategy is straightforward: if the firm is ready to file, file. The optionality of holding back has diminishing value as the deadline approaches.

What should you look for in counsel for a transitional file?

Speed of dossier preparation, judgment on operating-history disclosure, and active pre-clearance access at the home regulator — three things that matter more on transitional files than on new-entrant work.

Three things matter more for transitional files than for new-entrant CASP work:

1. Speed of dossier preparation. The deadline is fixed. Counsel that can produce the dossier quickly without sacrificing quality is the binding constraint, not counsel that bills the most senior partner for the most hours.

2. Operating-history disclosure judgment. What to disclose, what to characterise as a material change, and how to present three years of operating data is a judgment call. Counsel that has made the call before is worth meaningfully more than counsel that hasn’t.

3. Regulator pre-clearance access. The Bank of Lithuania, the Estonian FSA, and the Czech National Bank all operate informal pre-clearance channels. Counsel with active access can pre-flag substance concerns before they become deficiency notices.

The firms in our index that have processed five or more transitional filings in 2025-2026 appear in the related-firms section below.