MiCA CASP Accounting in Estonia — From VASP to CASP Before 1 July 2026
Estonia chose an 18-month grandfathering window under MiCA Article 143(3). The window closes on 1 July 2026, which is both the terminus of Estonia's 18-month period (from MiCA's 30 December 2024 application date) and the EU-wide absolute cap. After that date, only firms granted a CASP authorisation by Finantsinspektsioon — or firms whose application is still under review following a timely filing — may continue regulated activity. We support the accounting, own-funds and safeguarding workstreams of the CASP dossier and the post-authorisation reporting regime.
The 2026-07-01 deadline — what it actually says
MiCA Article 143(3) reads: "Crypto-asset service providers that provided their services in accordance with applicable law before 30 December 2024, may continue to do so until 1 July 2026 or until they are granted or refused an authorisation pursuant to Article 63, whichever is sooner." That text is reproduced verbatim in ESMA's December 2024 list of Member State grandfathering periods. Estonia appears on that list with an 18-month period. Latvia (6 months) and Lithuania (12 months) are already past their windows — remediation or new authorisation is now the only route there.
Read the rule carefully: the EU-wide hard cap is 1 July 2026. No Estonian grandfathering period extends beyond it. A firm that has not been either granted or refused a CASP authorisation by that date, and whose application is not under live review, must cease regulated activity.
Pending ≠ authorised
ESMA's December 2025 statement on the end of the MiCA transitional periods reinforces the point that many firms miss: a pending authorisation does not extend operating rights past the grandfathering end-date by default. A timely-filed application creates a review-period bridge while Finantsinspektsioon works through the dossier, but the firm cannot treat that review period as a continuous licence. It is a conditional bridge, not a renewal.
We advise clients to file early, file complete, and to build the post-2026-07-01 operating plan on the assumption that the authorisation must be granted, not merely filed. The business risk of confusing those two states is existential.
What the Finantsinspektsioon dossier requires
Finantsinspektsioon charges a €3,000 processing fee for a CASP authorisation and expects a full dossier: governance and management structure, documented internal control environment, own-funds computation meeting MiCA thresholds, client-asset segregation policy, ICT risk framework, AML/CFT programme with an appointed MLRO, and conflicts-of-interest procedures. Our scope covers the accounting and financial-reporting subset — own-funds schedules, safeguarding design, opening balance sheet, reporting taxonomy — and we coordinate with the legal counsel and technology lead on the rest.
From 18 March 2026, applications for an operating licence to issue asset-referenced tokens must be submitted through the Finantsinspektsioon application portal. For CASP services more broadly, the FSA published page is the operational source of truth.
Latvia and Lithuania — remediation, not preparation
Latvia's 6-month window expired around 30 June 2025. Lithuania's 12-month window expired around 30 December 2025. For LV and LT, there is no forward-looking "preparation" framing left: the only available route is a fresh MiCA CASP authorisation under the normal regime, or — for firms that continued operating without either grandfathering or authorisation — remediation with the competent authority (FKTK / Latvijas Banka for LV; Lietuvos bankas for LT).
Related questions
What happens to my VASP licence after 1 July 2026?
Estonia's VASP regime transitions to MiCA's CASP authorisation on 1 July 2026. Firms that filed a CASP application in time get a review-period bridge, but an application filed is not an authorisation granted — it cannot be treated as a continuous operational licence. Firms without a filed application must cease regulated activity by the deadline.