MiCA Licence Renewal in Europe: Keeping a CASP (2026)

Most operators plan carefully for winning a crypto licence and far less for keeping it, which is where authorisations are usually lost. Under MiCA, a CASP authorisation is a standing set of obligations under continuous supervision, and in our experience most operators budget for the application and nothing for what comes after. The result is avoidable: capital that drifts below the minimum, reports filed late, a DORA gap flagged at review. Here’s what it actually takes to keep an EU crypto licence live in 2026.

”Renewal” under MiCA means continuous compliance

The word “renewal” is slightly misleading for an EU licence. Unlike an offshore VASP permit that you re-pay annually, a MiCA CASP authorisation continues indefinitely, as long as you keep satisfying the conditions on which it was granted. There’s no expiry date to renew against; instead there’s a standing supervisory relationship. Your “renewal” is really the ongoing discipline of staying compliant, reporting on schedule, and keeping the regulator informed. Fail that, and the authorisation can be conditioned, suspended or withdrawn — which is functionally worse than an expiry, because it’s on the record.

MiCA licence renewal: triggers, timeline and the 1 July 2026 deadline

Because a CASP authorisation has no expiry date, “MiCA licence renewal” is a set of triggers that force regulatory action on their own timelines, with no fixed anniversary filing. These are the ones that matter:

The deadline everyone should have circled was 1 July 2026. MiCA’s Article 143 let each member state grant legacy providers a transitional (“grandfathering”) window of up to 18 months, running from 30 December 2024, so the outer boundary was 1 July 2026 and no member state could extend grandfathering beyond it. Several states set shorter windows: Germany and France, among others, closed theirs earlier. If you were relying on a pre-MiCA national VASP registration, that window was the one true “renewal” clock in the whole regime. Missing it carries no lapse-and-reapply grace; you lose the right to serve EU clients until a fresh CASP authorisation issues.

Everything else on that list is continuous rather than dated: you keep the authorisation live by hitting the reporting calendar, notifying material changes before they happen, and never letting own funds or insurance cover drift below the required minimum. Treat those as the real renewal work — the section below is what that maintenance looks like in practice.

The 2026 picture: the transition closed, supervision has begun

For most of MiCA’s rollout, the conversation was about getting in. That phase is over. The transitional period for legacy national VASP registrations closed on 1 July 2026 with no extension, and by late July more than 300 CASPs were authorised across the EU/EEA, licensed by national regulators and passporting across the bloc. The centre of gravity has shifted from application to supervision, which is where MiCA licence renewal now happens.

That matters because a large, freshly-authorised population is now entering its first full supervisory cycle at the same time. First annual reports, first prudential filings, first DORA testing evidence, first change-of-control notifications — all landing on regulators who now have a register to police rather than a queue to process. The scrutiny that felt light during a rush of authorisations tends to sharpen once the register stabilises, so expect supervisors to examine ongoing compliance more closely than they examined the original files.

What you must maintain, continuously

Capital is the one that catches operators out most often. It is a floor you must stay above every day, held as own funds, an insurance policy or both, at the higher of the class minimum or a quarter of last year’s fixed overheads. The three CASP capital classes set the starting level, and dipping below it, whether after a bad quarter, a large withdrawal or an FX move, is a reportable breach.

Why licences get withdrawn — and how to avoid it

The reasons regulators withdraw or condition a crypto authorisation are consistent and, almost always, preventable:

• Capital shortfalls — own funds slipping below the minimum without a remediation plan.
• AML and reporting failures — a dormant MLRO function, late filings, weak monitoring.
• Unnotified changes — a new shareholder, service or business model the regulator learns about after the fact.
• DORA and resilience gaps — inadequate ICT risk management, untested incident response, or unmanaged third-party providers.

Each of these is a governance problem rather than a legal one, which is why the fix is an ongoing-compliance function that owns capital monitoring, the reporting calendar, and regulator correspondence, rather than a one-off application team that moves on after issuance.

An old national registration no longer covers you

There’s a related trap specific to 2026: operators who still hold an old national VASP registration and assume it keeps working. Inside the EU it doesn’t. MiCA has replaced the national regimes, and every member state’s transition window had closed by 1 July 2026, so a firm without a CASP authorisation has lost the right to operate entirely. Our MiCA explainer and VASP vs CASP guide cover the conversion, which is now the only route back to serving EU clients.

For the gaming side of the same job (annual fees by jurisdiction, what regulators ask for at renewal and the four failure modes that make licences lapse), see our licence renewal service.

Ongoing compliance support for CASP holders

We provide ongoing compliance and renewal support for CASP authorisations obtained anywhere, including Lithuania, Estonia, Malta, Bulgaria and elsewhere in the EU. That means maintaining capital and reporting, running the MLRO/AML function, keeping DORA and policies current, and handling change-of-control filings and regulator correspondence, so your authorisation stays in good standing long after launch. If you hold a licence that needs a steadier hand, or an old registration that needs converting, book a free consultation and we’ll take it on end to end.

Christina S.

Crypto Licensing at Vantegris

Christina S. is part of the Vantegris team, which prepares and files licence applications across 40+ jurisdictions. This article was reviewed by Vladyslav S. (Compliance & Legal).

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This article is for general informational purposes only and is not legal, tax or financial advice. Consult a qualified professional before acting.