MiCA's EBA Transition Period Is Over. What Happens to CASPs That Missed It?

On 2 March 2026, the EBA's No Action Letter transition period on the interplay between PSD2 and MiCA came to an end. The EBA has now published its opinion on what national competent authorities should do next.

Three scenarios apply to CASPs that were carrying out Electronic Money Token (EMT) transactions qualifying as payment services:

**Scenario 1:** CASPs that obtained PI or EMI authorisation, or partnered with an authorised payment service provider, may continue operating.

**Scenario 2:** CASPs that submitted an authorisation application but have not yet received a decision may continue — subject to specific criteria set by their national regulator.

**Scenario 3:** CASPs that have not submitted an application, or that fail to meet the Scenario 2 criteria, must cease providing EMT services and offboard clients.

This is not a hypothetical. National regulators across the EU are now expected to act. Firms in Scenario 3 face the prospect of forced client offboarding — a reputational and operational crisis that is entirely avoidable with proper planning.

At COMPLaiNCE, we help CASPs navigate the MiCA transition — from authorisation strategy to regulatory correspondence.

**Source:** [EU CryptoReg Roundup February 2026, Walkers Global](https://www.walkersglobal.com/en/Insights/2026/03/EU-CryptoReg-Roundup-February-2026)