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ARTICLE · 25 JULY 2025

CASP Compliance Deadline. January 2026 Looms.

GTG Legal
GTG Legal
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GTG Legal

GTG Legal

Since its founding in 1997, GTG has been at the forefront of Malta’s legal profession, blending...

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One of the more persistent misconceptions doing the rounds in crypto compliance circles is the idea that MiCAR doesn't really bite until July 2026.

United KingdomTechnology

One of the more persistent misconceptions doing the rounds in crypto compliance circles is the idea that MiCAR doesn't really bite until July 2026. It's half true. Article 143 of MiCAR allows crypto-asset service providers who are already authorised under national regimes to continue operating until that date, provided they submit their MiCAR application by the end of December 2024. The key word here is "provided". The transitional period exists, but it is not a holiday from compliance. Nor does it shield you from everything that comes next.

On the first of January 2026, DAC8 however becomes enforceable across the European Union and irrespective of any transitory regime being availed of. DAC8 is not MiCAR's junior cousin. It is an entirely separate regulatory instrument with its own reach, its own logic, and its own obligations. It will apply whether you are MiCAR authorised or not. It will apply whether you are based in the EU or not. It will apply if your

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