MiCA Countdown for EU Crypto Firms Nears – What Happens if Deadline Passes?

• When MiCA rolls out next year, EU crypto firms will have up to 18 months to comply with the regulation.
• Many member states have opted for a shorter implementation timeline of just a year.
• With the deadline looming, firms that aren’t MiCA-ready risk losing access to the EU market.

In the EU, the Markets in Crypto Assets (MiCA) legislation will soon impose new rules for any business that offers crypto services to its customers. Once the regulation enters into force on Dec. 30, crypto firms will have up to 18 months to comply with the new rules, with the designated financial regulator in each country setting the timeline for compliance.

But despite the looming deadline, a significant minority of affected firms remain uncertain about their compliance requirements.

1 in 5 Firms Unclear on MiCA Transition

Because the European Securities and Markets Authority (ESMA) has given member states discretion to apply transition arrangements, a patchwork of different compliance timelines apply across the bloc.

This has created some confusion among affected firms regarding their obligations during the transition period.

According to a survey of senior payments executives Clear Junction shared with CCN, 20% of crypto firms are unclear on compliance requirements during the transition from member states’ existing regimes to the new unified MiCA framework.

Uneven Implementation Timeline

As pointed out  by Kraken’s European policy lead Beata Sivak recently, leaving the timeline for the MiCA transition period up to the discretion of member states, “brings a little bit of unevenness” that undermines efforts to harmonize regulation across the EU.

“The industry will not be at the same starting point on the first of January next year,” she noted.

“Where you are will very much depend on which member state you choose as your home.”

Moreover, with less than three weeks to go until MiCA takes effect, countries are racing to pass the necessary legislation to enshrine the new rules in domestic law, creating further uncertainty for firms seeking clarity on their requirements during the transition period.

Ireland Sticks With 2025 Deadline

Nowhere in the EU is MiCA implementation more consequential than in Ireland, which is home to some of the largest FinTech and crypto firms operating in the EU.

In a letter to the Department of Finance, the Electronic Money Association (EMA), which counts Circle, Coinbase and Gemini among its members, called on the regulator to extend the MiCA registration deadline  to the full 18 months allowed by the legislation.

Utilizing the maximum implementation period would “provide adequate time for both [crypto asset service providers] and the regulator to prepare for compliance with, and application of the new regime.”

“This will promote uniform application of the rules, prevent regulatory arbitrage, and mitigate the potential for market disruption to the benefit of consumers, CASPs, and supervisors,” EMA added.

Although the EMA represents the interests of its members across the EU, its decision to lobby for an extended grace period in Ireland suggests that businesses based there face the biggest challenges when it comes to getting MiCA-ready.

Despite the organization’s lobbying efforts, Ireland’s central bank opted for  a 12-month transition period ending on Dec. 29, 2025.

Crypto Companies Face Losing Access to EU Market

Under the MiCA regulation, any businesses that offer crypto asset services will need to be registered with a relevant EU authority. Firms can register as either a crypto asset service provider (CASP) or a regulated financial institution.

Any businesses offering crypto asset services in the EU without the necessary permissions after the implementation deadline will be in breach of the law. Regulators could then move to restrict non-compliant businesses’ ability to serve customers. They could also impose fines or pursue further legal action if warranted.

For crypto firms with a large EU customer base, operating in violation of the MiCA rulebook could be catastrophic. And with the EU already looking toward the next wave of crypto regulation, the cost of non-compliance is only going to increase.