CySEC MiCA Application Deadline 2026 – Existing CASPs

The Cyprus Securities and Exchange Commission (CySEC) has confirmed the MiCA application deadline 2026 for existing CASPs authorised under the Cyprus national regime, setting the final timeline for transition to the EU Markets in Crypto-Assets Regulation (MiCA).

In its press release dated 23 December 2025, the Cyprus Securities and Exchange Commission (CySEC) confirmed that existing CASPs authorised under the Cyprus national regime must submit a MiCA authorisation application by 27 February 2026. CASPs that meet this requirement may continue operating during the transitional period until their application is approved or rejected, or until 1 July 2026, whichever occurs first.

This clarification provides regulatory certainty. It also fixes the planning horizon for boards, management teams, and compliance functions. For existing CASPs, the focus now shifts to application readiness, submission quality, and regulatory engagement.

Regulatory background: MiCA and the Cyprus transitional regime

MiCA is established under Regulation (EU) 2023/1114 and introduces a harmonised authorisation and supervisory framework for crypto-asset service providers across the European Union.

As a directly applicable EU Regulation, MiCA replaces national CASP licensing regimes once fully applicable, subject to limited transitional arrangements. Cyprus has implemented a time-limited transitional regime for CASPs that were lawfully operating under national law prior to MiCA’s application.

This transitional regime allows existing CASPs to continue providing crypto-asset services for a defined period, provided that a MiCA authorisation application is submitted within the timeframe set by CySEC. The arrangement is intended to support an orderly transition rather than a prolonged parallel regime.

The CySEC press release: what was confirmed

CySEC’s press release dated 23 December 2025 specifically addresses existing CASPs authorised under the Cyprus national regime and confirms the following:

• Application deadline:
  A complete MiCA authorisation application must be submitted no later than 27 February 2026.
• Continued operation during transition:
  Existing CASPs that submit a timely application may continue operating under the national regime until a decision is issued or until 1 July 2026, whichever occurs first.
• Wind-down obligation:
  Existing CASPs that do not submit an application by the deadline will be required to prepare an orderly wind-down plan, as the provision of crypto-asset services under the national regime will no longer be permitted after the transitional period ends.

The press release confirms how the transitional framework will be applied in practice and removes uncertainty around key dates.

Who is affected by this update

This regulatory update is relevant to:

• Existing CASPs authorised under the Cyprus national regime
• CASPs providing cross-border services from Cyprus to clients in other EU Member States
• Groups planning to rely on Cyprus as their MiCA home Member State
• Firms involved in corporate transactions concerning an existing CASP

Entities that are not currently authorised under the national regime are not eligible for transitional treatment and must apply directly under MiCA.

What existing CASPs must do by 27 February 2026

Existing CASPs must submit a complete MiCA authorisation application to CySEC by 27 February 2026.

In practice, this requires demonstrating that the CASP meets MiCA requirements across governance, compliance, and operations. Key areas include:

• Governance and management arrangements
  Clear allocation of responsibilities, management body suitability, and documented oversight structures.
• Risk management and internal controls
  Proportionate frameworks supported by evidence of implementation.
• AML/CTF and crypto-asset transfer obligations
  Alignment with Regulation (EU) 2023/1113, including Travel Rule controls and monitoring processes.
• Safeguarding of client assets
  Segregation, custody arrangements, and reconciliation processes.
• Operational and IT arrangements
  Systems resilience, outsourcing oversight, and incident response capabilities.

In current MiCA readiness engagements, recurring challenges include gaps between documented policies and operational practice, as well as inconsistencies across application materials. These issues are typically addressed through structured MiCA CASP licensing preparation well in advance of submission.

The transitional period: what continued operation means in practice

CySEC’s confirmation of continued operation during the transitional period is conditional and time-limited.

Existing CASPs may continue providing crypto-asset services only if:

• A MiCA application is submitted by 27 February 2026, and
• The transitional period has not yet expired.

The transitional period ends on 1 July 2026, unless CySEC issues a decision earlier. There is no automatic extension beyond this date.

For CASPs providing services to clients in other EU Member States, continued cross-border activity remains subject to host Member State requirements and the application of any grandfathering provisions in those jurisdictions. This often requires jurisdiction-specific regulatory analysis.

Consequences of not submitting a MiCA application

Existing CASPs that do not submit a MiCA application by the deadline face a defined regulatory outcome.

CySEC has confirmed that such firms will be required to prepare an orderly wind-down plan, which typically involves:

• Cessation of crypto-asset services
• Client communication and asset return processes
• Operational, contractual, and compliance closures

The wind-down requirement reflects the end of the national regime, rather than an enforcement action. Boards should treat the decision not to apply as a strategic decision with regulatory, commercial, and reputational implications.

Supervisory focus areas emerging from MiCA preparation

Although the CySEC press release is factual in nature, it aligns with broader supervisory themes emerging across MiCA implementation.

In recent MiCA preparation work with existing CASPs, the following areas are frequently in focus:

• Substance over form in governance arrangements
• Operational realism in business and outsourcing models
• Consistency across policies, procedures, and workflows
• Early engagement and realistic implementation timelines

These themes reinforce the importance of preparation that reflects how the business operates in practice.

Practical planning considerations for boards and management

For boards and senior management, the confirmed deadline creates several immediate priorities:

• Assigning clear internal ownership of the MiCA transition
• Mapping preparation steps backwards from the 27 February 2026 deadline
• Ensuring adequate resourcing and decision-making capacity
• Considering contingency planning in case of delays or refusal

Short decision cycles and early clarity tend to support smoother regulatory engagement.

How CX Financia supports MiCA authorisation

CX Financia works with existing CASPs authorised under the Cyprus national regime throughout the MiCA authorisation process.

Support typically includes:

• MiCA readiness and gap assessments
• Structuring and reviewing authorisation applications
• Alignment of governance, compliance, and operational frameworks
• Support during regulatory engagement with CySEC
• Post-authorisation compliance planning

Further information on our CASP Licensing Service in Cyprus is available for firms assessing their next steps towards MiCA authorisation.

Closing note

CySEC’s December 2025 press release provides clear confirmation of the final phase of the MiCA transition for existing CASPs in Cyprus. With deadlines now fixed, preparation efforts should focus on application quality, governance substance, and operational readiness.

Early, structured action remains the most effective way to manage regulatory risk and ensure continuity under MiCA.

Key dates and takeaways

• MiCA application deadline: 27 February 2026
• End of transitional period: 1 July 2026
• Who is affected: Existing CASPs authorised under the Cyprus national regime
• Key regulations: Regulation (EU) 2023/1114 and Regulation (EU) 2023/1113
• Regulator: Cyprus Securities and Exchange Commission (CySEC)