MiCA’s transitional rules require a granted CASP authorization (not just an application) by July 1, 2026. Many EU Member States set domestic application deadlines in mid–late 2025 that have already passed, so pre‑MiCA VASPs in those jurisdictions have lost grandfathering. National VASP registrations never passported across states, cross‑border activity needs separate filings or full CASP authorization, and reverse solicitation is a narrow exemption likely unavailable to providers that targeted EU users. Pending applications do not allow continued operation past the hard deadline. Firms lacking a competent national authority (e.g., Poland, parts of Romania) cannot file domestically and may have to cease services. Banks are warning VASP‑only clients they may withdraw services absent proof of a CASP application or license; continuity paths include restructuring into jurisdictions with functioning CASP processes and genuine substance.

Facts: MiCA requires a granted CASP authorization by July 1, 2026; many Member States set application deadlines in June–December 2025 that have passed, removing grandfathering for pre‑MiCA VASPs. National registrations never passported, reverse solicitation is narrowly assessed, pending applications do not permit continued operation, and jurisdictions without a designated Competent Authority prevent filings — banks are already warning VASP clients. These concrete, regulatory constraints increase operational risk for affected providers.