·Fintech Accounting
77 Days Left: What the Estonian VASP-to-CASP Transition Looks Like From Here
Today is 14 April 2026. Estonia's 18-month MiCA grandfathering window under Article 143(3) closes on 1 July 2026 — 77 days away. This post is a practitioner's update on where dossiers realistically stand, why a pending application is not a continuous licence, and what we are doing with clients who still have a shot at authorisation before the cap.
The date that actually matters
The EU-wide hard cap on MiCA grandfathering is 1 July 2026. No national transition period extends past it. Estonia chose the full 18-month window under Article 143(3), counted from MiCA's 30 December 2024 application date, which lands exactly at the EU cap. Latvia's 6-month window expired around 30 June 2025; Lithuania's 12-month window expired around 30 December 2025. Only Estonia still has usable runway in the Baltics — and that runway is now 77 days.
From 1 July 2026, a firm that does not hold a CASP authorisation under Article 63, and whose application is not still in live review by Finantsinspektsioon, must stop regulated activity. It is not a soft landing. Planning the next quarter around anything else is a category error.
Why "we've filed" is not the plan
ESMA's December 2025 statement on the end of the transitional periods was blunt on a point many firms still misread: a pending authorisation does not by itself extend operating rights beyond the grandfathering end-date. Timely filing creates a conditional review-period bridge while the supervisor works the file. That bridge is conditional on the dossier being complete enough to review, and on the competent authority actively processing it. It is not a renewal.
We have seen two failure modes this month. The first is firms treating "submitted" as "approved" — running 1 July 2026 into their roadmap as if it is a paperwork date. The second is firms filing thin dossiers in a rush, which immediately trigger completeness requests and burn the runway they were trying to protect. Neither is recoverable in 77 days without discipline.
What goes in front of Finantsinspektsioon
The CASP authorisation dossier that Finantsinspektsioon reviews is broad: governance and management structure, documented internal controls, an own-funds computation meeting the MiCA thresholds, a client-asset segregation and safeguarding policy, an ICT risk framework, an AML/CFT programme with a named MLRO, and conflicts-of-interest procedures. The processing fee is €3,000 for a CASP authorisation. From 18 March 2026, applications for an operating licence to issue asset-referenced tokens must be submitted through the Finantsinspektsioon application portal. For broader CASP services, the Finantsinspektsioon published page is the operational source of truth.
Our practice covers the accounting and financial-reporting slice of that dossier. That is own-funds schedules, safeguarding design, the opening balance sheet under the new perimeter, and the reporting taxonomy that will land with the supervisor post-authorisation. We coordinate with legal counsel on governance and with the technology lead on ICT risk — but we are responsible for the numbers behind the narrative.
What we are actually doing this week
With 77 days on the clock, the operational pattern is tight. Monday through Wednesday we reconcile own-funds schedules and test them against the MiCA thresholds at the revised perimeter. Thursdays we run MLRO tabletops so the documented AML programme matches the programme the firm can actually execute. Fridays we stage the safeguarding and segregation evidence for the submission bundle. Every week we check pre-July filings for completeness gaps before they come back as a question from the supervisor.
If you are a Baltic firm still carrying a VASP licence and you have not yet moved on the CASP dossier, the next conversation is about whether authorisation before 1 July 2026 is realistic, and — if not — which post-deadline path actually works. That is a structured conversation, not a sales call. Book one through the contact page.