Luxembourg Crypto Firms Need MiCAR Approval After July 1, 2026 Deadline
Updated
Updated · K&L Gates · Jul 8
Luxembourg Crypto Firms Need MiCAR Approval After July 1, 2026 Deadline
3 articles · Updated · K&L Gates · Jul 8
Summary
July 1 ended MiCAR’s 18-month transition, leaving any Luxembourg crypto-asset service provider without MiCAR authorisation operating illegally.
Former VASP registration under Luxembourg’s AML law no longer suffices; firms must hold a full CASP licence or, if eligible financial entities, complete MiCAR’s article 60 notification.
ESMA said unauthorised firms should immediately stop taking new EU clients and marketing, then limit activity to asset transfers, sales and position closures while informing clients of wind-down deadlines.
IFMs, depositaries and credit institutions must now verify counterparties on the ESMA register, reassess article 60(5) exposure and review custody and fund documents because an unauthorised CASP can create direct fund-level risk.
MiCAR has applied across the EU since December 30, 2024, and Luxembourg’s CSSF can now pursue supervisory action and potential client-liability cases with no further grace period.