Given that some MiCA transitional periods have already ended or are close to expiring and considering that market participants have had sufficient time to use these periods to engage in MiCA authorisation, ESMA’s statement highlights:

1. CASP responsibilities:

• CASPs must prioritise compliance with MiCA, including applying for authorisation promptly.
• CASPS not yet authorised are expected to implement orderly wind-down plans for services in jurisdictions where transitional periods have ended or are nearing conclusion. These plans should ensure minimal disruption to clients, such as facilitating the transfer of crypto-assets to authorised providers.

2. National Competent Authorities (NCAs):

• NCAs must closely monitor CASPs' cross-border activities and maintain ongoing dialogue with other Member States to mitigate disruptions caused by varying transitional timelines.
• "Last-minute" MiCA applications should be scrutinised rigorously, with unauthorised CASPs potentially required to cease operations during the review process.
• Prepare for enforcement against the unauthorised provision of crypto-asset services.

3. Investor advisory:

• Investors should verify that their CASP is authorised under MiCA by consulting the ESMA Interim MiCA Register. Engaging with unauthorised entities may result in a lack of regulatory protections.

ESMA emphasises the importance of early preparation by CASPs and proactive engagement with NCAs to ensure a smooth transition to MiCA compliance, safeguarding market integrity and investor interests.

ESMA’s statement can be found here