MiCAR In Full Force: Key Considerations For CASP Applications And Notifications In Luxembourg

With the expiry of the transitional regime for virtual asset service providers on 1 July 2026, the Markets in Crypto-Assets Regulation (MiCAR) is now fully operational as the EU’s harmonised framework for crypto-asset services. Firms seeking to provide crypto-asset services must either obtain a CASP authorisation or, where eligible, rely on a simpler notification regime to extend an existing regulated licence.

Early interactions with the Luxembourg Commission de Surveillance du Secteur Financier (CSSF) show that, irrespective of the route chosen, significant emphasis is placed on the quality, completeness and consistency of the information provided. In addition, third-country groups seeking to access the EU market through Luxembourg should carefully assess the CSSF’s expectations regarding local substance, governance arrangements and the organisation of crossborder activities at an early stage. With an increasing number of CASP licences now being granted in Luxembourg, developments