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MiCA: The End of the Transition Period in the EU and an Initial Assessment
As of July 1, 2026, the MiCA transition period will end in the EU.
Of the thousands of entities that operated in the crypt under various national regimes across the EU/EEA, there are currently more than 240 authorized providers remaining, six of which are based in Slovakia.
For me, as a lawyer, this was the first time I was able to actively participate in the implementation of a completely new regulation in the financial sector. Based on the realities in Slovakia, particularly from the perspective of a legal advisor, I would like to offer a few observations:
▪️CONTINUITY AMONG EXISTING PLAYERS AND CAUTION ON THE PART OF FINANCIAL INSTITUTIONS
All Slovak licenses have so far been issued in the “first wave” at the turn of 2025 and 2026. In practice, these were mainly existing players who were already operating in the crypto space before MiCA, such as Fumbi, Okazio or Crypto Voucher. As an exception, I’d like to mention the newcomer MadisonSix.
On the contrary, Slovak financial institutions have not yet entered this sector. This stands in stark contrast to Western Europe, where the entry of financial institutions has been very strong in some countries—for example, in Spain with domestic banks such as CaixaBank and BBVA.
▪️MiCA and DORA: A Two-Pronged Approach to New Regulation
I saw this as a huge challenge not only for applicants but also for us as consultants, I saw not only the transition from virtually “zero” regulation of VASPs in Slovakia to a fully regulated CASP regime, but also the need to adapt to the rules of digital operational resilience under DORA and a whole range of related Level 2 regulations.
In this regard, I feel that the market has already gotten used to DORA. After the initial shock, it is increasingly becoming the norm, and applicants are better prepared for it.
▪️Stablecoins and PSD2
Another practical challenge has been—and continues to be—adapting existing business models related to stablecoins so that they do not overlap with payment services.
On the one hand, it is possible to provide many common cryptoasset services in connection with stablecoins under certain conditions. On the other hand, when providing legal advice, we continue to encounter the limitations of these business models.
▪️CRYPTO DERIVATIVES
The overlap between the legal framework governing crypto-assets and MiFID II predates MiCA. However, MiCA has created an opportune moment to bring order to this area as well and to tighten oversight of financial instruments that are crypto-assets.
This product is practically nonexistent in Slovakia (aside from foreign providers); I’ll be curious to see if any financial institution takes the lead in this area.
▪️WHAT’S NEXT FOR THE SLOVAK MARKET?
Operating domestic entities have already succeeded in obtaining licenses. The current applicants—at least those we have on record—are primarily companies with foreign ownership, which presents its own unique challenges in the licensing process. In any case, we expect the number of new proceedings to gradually stabilize, as has been the case in other financial sectors.
MiCA is a relatively new regulation and will naturally continue to evolve as it is applied in practice. However, I would venture to say that, at least from the perspective of CASP regulation, it has been a success story so far.
