Digital asset compliance — MiCA transitional window closing

Executive briefing: Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA) grants member states the option to allow existing crypto-asset service providers (CASPs) to continue operating under national licences until 30 December 2025. With only two months remaining as of 30 October 2025, exchanges, custodians, and token issuers must finalise MiCA-compliant governance, prudential, and consumer protection frameworks to avoid business interruption when the transitional window closes.

Compliance checkpoints

Authorisation dossiers. Articles 62–67 outline documentation requirements for CASP authorisations, including programme of operations, IT security policies, and safeguarding arrangements.
Governance and prudential. Articles 72–75 impose fit-and-proper management, complaint handling, and prudential safeguards (own funds or insurance) that many national regimes do not fully cover.
Market abuse controls. Title VI requires CASPs to implement market abuse detection, surveillance, and reporting procedures similar to MiFID II obligations.

Operational build

Complete MiCA gap assessments across custody, trading, and issuance functions, mapping controls to regulatory articles.
Upgrade safeguarding of customer assets, segregation procedures, and incident reporting to meet Articles 75 and 76.
Deploy surveillance tooling and compliance staffing to monitor for insider dealing, market manipulation, and unlawful disclosure.

Enablement moves

Engage with national competent authorities to lock authorisation review timetables and remediation expectations.
Refresh consumer disclosures—white papers, risk statements, and complaint channels—to align with MiCA templates.
Coordinate with banking partners on safeguarding and capital arrangements to avoid service disruption at year-end.

Sources

Zeph Tech helps CASPs navigate MiCA authorisation—building governance, market surveillance, and prudential controls ahead of the transitional deadline.