While a number of CASPs will have obtained authorisation by 1 July 2026, other entities, including significant providers currently servicing EU clients under national regimes, may not be authorised by the deadline.

ESMA expects unauthorised CASPs to take immediate steps to wind down their EU activities in an orderly manner, while also safeguarding clients’ interests and mitigating risks to market integrity ⁽²⁾. In particular, unauthorised CASPs must:

• immediately stop onboarding new EU clients, refrain from opening new client relationships or accounts, and cease marketing activities and solicitation. 
• limit the provision of services to actions necessary to sell or transfer crypto-assets, reallocate assets, or close positions. Custody of…