The Regulation has applied in full since December 2024 and the transitional window for existing providers ran out on 1 July 2026. Advice and transfer services are inside the licensed perimeter, the provider must actually sit in the Union, and marketing into the Union closes the reverse-solicitation door.
The grace period has closed
MiCA, the EU's rulebook for crypto-asset services, has applied in full since 30 December 2024, with the stablecoin parts running from 30 June 2024. Firms that were already providing crypto services lawfully before that date were given room to carry on: until 1 July 2026, or until their licence application was granted or refused, whichever came first.
That outer date has now passed. Countries were also free to drop the grace period or shorten it where their own rules were already stricter, and each had to say which by 30 June 2024. So what applied in any particular country, and for how long, is a national question to confirm rather than something to read off the EU text.
What needs a licence
The starting point is a ban, not a licensing scheme: nobody may provide crypto-asset services in the EU unless they are authorised as a crypto-asset service provider — or unless they are one of the listed financial firms (a bank, investment firm, e-money institution, fund manager and so on) allowed to provide them on the back of the licence they already hold.
The services themselves are defined, and the list is wider than “running an exchange”:
holding crypto-assets for clients, including control of the keys;
running a trading platform;
exchanging crypto-assets for money, or for other crypto-assets;
executing orders, receiving and passing on orders, and placing;
advice on crypto-assets and portfolio management;
transfer services for clients.
Advice and transfers are the two that catch businesses who do not think of themselves as crypto firms at all.
Where the firm itself has to be
An authorised provider has to have its registered office in an EU country where it actually carries out at least part of its services, its real management in the EU, and at least one director living in the EU. A letterbox in one country serving clients from outside the EU does not meet that.
“The client came to us” — and how narrow that is
There is a small opening. Where a client in the EU approaches a non-EU firm entirely on their own initiative, the firm does not need an EU licence for that service for that client.
The next sentence closes most of it. If the non-EU firm — including through anyone acting for it or closely connected to it — approaches clients or potential clients in the EU, by any means of communication, promotion or advertising, then the service is not treated as the client's own initiative. Marketing into the EU and then pointing at the client's own sign-up form does not work.
Tokens that were already trading
For crypto-assets other than stablecoins that were already admitted to trading before 30 December 2024, only part of the rulebook applies. Marketing communications published after that date are covered. And trading platforms have until 31 December 2027 to make sure a white paper exists, has been notified and published, and is kept up to date where the rules require one. Public offers that had already ended before 30 December 2024 are outside those requirements altogether.
What to check
Whether anything you do falls into the list of services above — advice and transfers especially.
Whether your licence has been granted, refused or is still pending, and what your country decided about the grace period.
Whether your marketing reaches the EU, because that decides whether the “client came to us” route is open to you at all.
If you run a platform with older listings, whether the 2027 white-paper deadline is in anyone's plan.
Supervision and penalties sit with the national authority, and which Latvian authority that is, with what powers, is worth settling locally.