1) Transitional period expiry

• ESMA states that the MiCA transitional period “will officially expire across the EU on 1 July 2026” and after 1 July 2026, any entity providing crypto-asset services to EU clients without a MiCA licence will be “in breach of EU law” and “must cease offering such services”.
• ESMA also underlines that the prohibition applies irrespective of whether MiCA has been implemented in a Member State or not, reinforcing the pan‑EU compliance cut‑off.

2) Wind-down obligations for unauthorised CASPs

ESMA reiterates following its related statement of 4 December 2025 that CASPs unauthorised by that date should have orderly wind‑down plans “ready for implementation” if authorisation is not obtained by the relevant deadline. ESMA expects wind‑down plans to:

• Wind-down plans must be operational, credible, and immediately executable, designed in compliance with applicable EU conduct, prudential, and AML/CFT obligations.
• Plans must facilitate orderly client offboarding, including by arranging the transfer of crypto-assets held on behalf of clients to an authorised CASP or to a self-hosted wallet, with prior notice to affected clients.
• By 1 July 2026, unauthorised CASPs must have already implemented their wind-down plans — the mere existence of a plan on paper will not suffice.

3) Client migration

• At the same time, ESMA expects authorised CASPs to “actively manage” migration of existing clients ahead of 1 July 2026, including taking steps to onboard EU clients before the expiry of the transitional period.
• ESMA expressly links such onboarding to robust AML/CFT processes and “full compliance” with applicable AML/CFT requirements, signalling limited tolerance for simplified procedures during mass migration.

4) Third‑country perimeter, reverse solicitation and anti‑circumvention

• ESMA further reminds market participants that entities established outside the EU are (save for those relying on the reverse‑solicitation exception) prohibited from providing crypto-asset services to EU clients or soliciting EU clients with a view to providing such services.
• ESMA further reaffirms that this restriction applies also in a B2B context and notes that MiCA prohibits CASPs from outsourcing/delegating certain services to non-EU entities which are not authorised as CASPs under MiCA.

5) Expectations on NCAs: verification and enforcement

ESMA’s expectations for NCAs ahead of and after expiry, including:

• verifying the existence and adequacy of wind‑down plans and ensuring timely implementation without undue economic harm to clients.
• acting against the unauthorised provision of crypto-asset services post‑expiry of the transitional period (including cooperation with other authorities where appropriate); and
• scrutinising client migration strategies, including to ensure unauthorised CASPs do not continue “business‑as‑usual” beyond the transitional period.

6) Investor-facing warnings

Finally, ESMA directs investors to verify whether a provider is authorised as a CASP in the EU. ESMA stresses that MiCA protections apply only when dealing with specific EU-authorised CASPs, not other group companies and not non‑EU entities, even where a common brand is used across jurisdictions.

ESMA’s statement can be found here.