Eighteen months after MiCAR became fully applicable, the clock for the transitional regime is now running down: on 1 July, the grandfathering period will expire and CASPs without a MiCAR licence will have to cease operations.
Over this period, MiCAR has established a harmonised crypto-asset framework that promises consumer protection and legal certainty. These benefits are real. So are the friction points: overlapping licensing requirements, classification ambiguities, and a grandfathering period that is running out faster than most market participants anticipated.