Transitional periods and their end on 1 July 2026

Read the PDF edition (1 page)

Art. 143 governs the transition. Offers that ended before 30 December 2024 need no white paper. Crypto-assets admitted to trading before that date need a white paper only by 31 December 2027 at the latest, with marketing rules applying from 30 December 2024. Providers that lawfully operated under national law before 30 December 2024 could continue until authorised or refused under Art. 63, but no later than 1 July 2026. Member States could shorten that eighteen-month period, and several did: ESMA's published list records grandfathering periods ranging from a few months to the full term.¹ Art. 143(6) allowed a simplified authorisation procedure for firms already authorised under national law.

As of 30 June 2026 the grandfathering has ended across the Union. A firm serving Union clients from a Union entity that has not obtained CASP authorisation is operating unlawfully, and the competent authorities have said they will treat the date as a hard stop. For Swiss and Singapore groups this changes the assessment of Union counterparties. A Zug exchange's liquidity provider in Lithuania or a Singapore custodian's sub-custodian in Germany must now hold CASP authorisation, and the Swiss or Singapore firm's own due diligence, under its AML and outsourcing rules, must check the ESMA register of authorised CASPs.²

Notes

Regulation (EU) 2023/1114, Art. 143(1) to (3) and (6). Member States had to notify the Commission and ESMA of any shortened period by 30 June 2024. ESMA, "List of MiCA grandfathering periods (Art. 143(3))", December 2024. ↩
ESMA maintains the register of CASPs and white papers under Art. 109. The register went live in 2025 and is the reference for counterparty checks. ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.

English

Contact

Dr Alexander Ressos, TEP

Of Counsel, KGP Legal LLC

I am Of Counsel with KGP Legal LLC in Singapore, where I work with a global client base of successful entrepreneurs and their families, independent asset managers, commodity trading houses and other commercial clients. I am a German and Swiss attorney-at-law, also admitted as a solicitor in England & Wales and in Hong Kong. I divide my time between Zug in Switzerland, Singapore and Hong Kong. Since 2017 I have advised international clients on more than 700 crypto and digital asset projects. I also have extensive experience in cross-border litigation and arbitration in Singapore, Hong Kong and other markets in South-East Asia and Greater China.

I operate across the key financial centres in South-East Asia, the Middle East and Switzerland, with a particular focus on asset protection, international tax and estate planning, as well as trusts, company administration and other fiduciary services. My philosophy is to serve as a trusted advisor working closely with my clients and to help them achieve their commercial objectives.

All Singapore law advice is provided through KGP Legal LLC, an established and duly licensed firm of Singapore advocates and solicitors.

KGP Legal LLC is a medium-sized law firm in Singapore that is capable of providing the full range of legal services and corporate administration work. Please contact me directly at [email protected] if you need any further information.

Get in touch →

Articles and Insights

Setting up or expanding in Singapore?

SingaporeIQ is edited by Dr Alexander Ressos, an international business lawyer with more than 15 years of local experience in Singapore as a permanent resident, a Singapore registered foreign lawyer and managing partner of a Singapore foreign law practice. In addition to significant experience in cross-border investments and transactions, UHNWI private client work and sanctions/export controls, Dr Ressos has extensive experience in cross-border business and in crypto and digital-asset projects in Singapore, drawn from more than 700 projects since 2017.

If you are planning a company incorporation, an investment, a holding structure or a market entry through Singapore, you can reach Dr Ressos directly at [email protected]. Singapore law advice is provided by KGP Legal LLC, a licensed firm of Singapore advocates and solicitors. As a Singapore law practice, KGP Legal LLC is authorised under the Legal Profession Act 1966 to advise on Singapore law and to represent clients before the Singapore courts; foreign law practices with an office in Singapore are, as a rule, not permitted to do either. Dr Ressos and his team facilitate the full range of Singapore legal, compliance and company administration services, including company incorporation, corporate transactions, commercial contracts, crypto and digital assets, financial regulatory work and dispute resolution, including litigation in the Singapore courts. For legal, tax and fiduciary services in Switzerland, see helveticaregister.com.