MiCA deadline 1 July: what now applies for crypto custodians and treasury

On this 1 July 2026, the last window of the Markets in Crypto-Assets Regulation (MiCA) closes. It is the EU-wide outer boundary of the transition period under Article 143(3): anyone providing crypto services in the European Union now needs full authorisation as a Crypto-Asset Service Provider (CASP). The European Securities and Markets Authority (ESMA) clarified in April that there will be no extension. For many market participants, however, the date has long since passed: Germany had already set the national deadline to 31 December 2025 through its Crypto Markets Supervision Act.

The deadline falls in a phase in which the EU's stablecoin rules are fiercely contested politically. The European Central Bank (ECB) warns of a dollarisation of digital payments and is pressing for a tightening. The European Commission has, in parallel, launched a consultation that points in the other direction. Anyone seeking to assess the situation operationally must keep both levels apart: what applies legally on 1 July, and the dispute over what should apply in future.

The deadline: what really happens on 1 July

From today, providing crypto services without a CASP licence is unlawful EU-wide. Providers without full authorisation must stop onboarding new customers, cease marketing and implement orderly wind-down plans. The state of licensing is sobering: in mid-June 2026, around 204 CASPs were authorised in the European Economic Area, 53 of them in Germany. Measured against the multitude of previously nationally registered providers, more than 80 per cent of former market participants have not yet achieved full authorisation.

For institutional players, custody is especially relevant. Anyone who safeguards and administers crypto-assets provides a licensable service under Article 3(1)(17) of MiCA. Treasury desks and asset managers working with custodians or trading venues should therefore review their counterparty risk: a service provider without a CASP licence may no longer conduct any legal new business in the EU from 1 July. For the large trading venues this is largely settled; venues such as Kraken, Coinbase, OKX and Bitpanda hold confirmed authorisations.

The stablecoin caps: Article 23 in detail

The most misunderstood part of MiCA is the ceiling for stablecoins. Article 23 caps non-euro e-money tokens (EMT): once a token denominated in a foreign currency exceeds the threshold of one million transactions per day or a daily volume of 200 million euros, measured as a quarterly average, the issuer must stop new issuance and submit a reduction plan. The often-overlooked restriction is decisive: the cap applies only to use as a means of exchange, not for investment or trading purposes. Swapping a dollar token for bitcoin does not trigger the cap. Euro-denominated EMTs are exempt in any case.

In practice, the norm is currently barely binding. Tether, by far the largest dollar stablecoin, is not seeking MiCA authorisation and was already delisted from EU-regulated trading venues by March 2025. Article 23 therefore applies above all to regulated dollar tokens such as Circle's USD Coin, which is issued MiCA-compliantly through a European entity. The relative sizes put the excitement into perspective: the global stablecoin market stands at around 309 billion US dollars, of which over 98 per cent are dollar tokens. Euro stablecoins together amount to about 450 million euros, less than 0.2 per cent of the world market.

The real dispute: ECB versus Commission

Behind the technical deadline lies an institutional power struggle. The European Systemic Risk Board (ESRB), in which the ECB plays a central role, recommended as early as 25 September 2025 that stablecoins issued jointly by EU and third-country entities be declared inadmissible under MiCA. ECB President Christine Lagarde has since raised the issue publicly several times, most recently in a speech on 8 May 2026 and at the informal meeting of EU finance ministers in Nicosia on 23 May. Her argument targets a run risk in such multi-issuance schemes.

As clear as the ECB's position is, its power to enforce it is limited. The central bank is not a legislator; it can recommend, give speeches and warn finance ministers, but it cannot legislate. The European Commission effectively rejected the ESRB recommendation in October 2025 and did not share its concerns about multi-issuance schemes to that degree. More notable still: on 20 May 2026 the Commission launched a consultation, with a deadline of 31 August, that explicitly asks whether the euro stablecoin rules should be loosened. A formal tightening of MiCA is not on the agenda; the next regular review report is only scheduled for 30 June 2027.

The second look: how real is the risk?

The sharpest counter-position to the ECB comes not from the industry but from academia. The think-tank Bruegel argues in a policy brief of 20 May 2026 that the ECB's therapy is counterproductive. Anyone who restricts stablecoins and favours the digital euro drives users all the more towards unregulated alternatives or self-custodied dollar tokens. There is also a systemic side effect: the MiCA obligation to hold a significant share (30 to 60 per cent) of reserves as bank deposits does protect against stablecoin runs, but in turn transmits bank risks into the tokens.

The figures support both the concern and the criticism. Europe accounts for around 38 per cent of global stablecoin transaction volumes, but only about 0.3 per cent of issuance volume is euro-denominated. The dollarisation is therefore empirically real. At the same time, the European stablecoin market, at around 450 million euros, is too small to pose an acute systemic risk; the ECB's scenarios for a market in the trillions are hypothetical. The industry, for instance through the Blockchain4Europe initiative, warns accordingly that the ban on interest, the strict reserve requirements and the caps structurally weaken the competitiveness of European stablecoins.

Recommended actions for operational practice

For institutions, custodians and treasury functions, 1 July is less a turning point than a moment of maturity. The regulatory substance stands; the political debate remains open. Five fields of action stand out.

Christian Schablitzki

Strategy & Management Consultant · Agentic AI expert for financial institutions

More than 20 years in investment banking and derivatives trading, followed by over 10 years advising financial institutions. Currently a Partner at Infosys Consulting in Germany. Certified in Google AI, Generative AI Leader (Google Cloud) and IBM RAG and Agentic AI.

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