WHAT CHANGED IN THE EU
The MiCA transition has ended
On 1 July 2026, the last MiCA transitional period ended across the EU. Estonia’s Financial Intelligence Unit cancelled its legacy virtual currency licences on that date, and Lithuania’s transition had already ended on 31 December 2025. Firms without MiCA authorisation must stop taking on EU clients. Many are now building or moving operations to Hong Kong. We advise on the Hong Kong side; your EU counsel should handle any EU wind-down or client transfer.
Need a Trust Licence? Does your business provide custodian services?
— holds or stores clients’ digital assets (e.g., BTC, ETH, stablecoins)
— safekeeps private keys or wallet access for clients
— offers escrow, safekeeping or asset management
— acts as a trustee or uses “trust” in its company name
— held an EU VASP licence that lapsed, was cancelled or was not renewed
Trust services in Hong Kong generally require a TCSP licence from the Companies Registry. A separate SFC licence for virtual asset custodians that safekeep clients’ private keys is being legislated, with the Government aiming to introduce the bill into the Legislative Council in 2026. If a previous EU licence was cancelled, refused or not renewed, we review how that history should be disclosed before you apply.