The MiCA Transition Has Ended: What Next for Estonian and Eastern European Crypto Firms?

On 1 July 2026, the last of the transitional periods under the EU Markets in Crypto-Assets Regulation (“MiCA”) came to an end [1][3]. Crypto businesses that had been operating under national registrations, such as the virtual currency licences issued by Estonia’s Financial Intelligence Unit (“FIU”), can no longer serve EU clients unless they hold a MiCA authorisation as a crypto-asset service provider (“CASP”) [1][4]. For many Estonian, Baltic and other Eastern European firms, this is the point at which the business must be authorised, wound down in the EU or restructured. This article summarises what changed, how the main Baltic and Polish markets are affected, and what firms should consider if they plan to rebuild their non-EU business through Hong Kong.

What Changed on 1 July 2026

MiCA has applied to CASPs since 30 December 2024. Article 143(3) allowed Member States to let existing providers continue under national law for up to 18 months, until 1 July 2026 at the latest [3]. ESMA, the EU securities regulator, has stated that after that date any entity providing crypto-asset services to EU clients without a MiCA licence is in breach of EU law and must cease those services, whether or not national law has been adjusted [1]. In its statement of 23 June 2026, ESMA said that unauthorised CASPs must:

• Stop onboarding new EU clients, refrain from opening new accounts and cease marketing and solicitation [2].

• Limit services to the actions needed to sell or transfer crypto-assets, reallocate assets or close positions. Custody may continue only for the period strictly necessary to complete an orderly exit [2].

• Communicate clearly and repeatedly with clients about the wind-down timetable, and maintain anti-money laundering and counter-terrorist financing (“AML/CFT”) controls throughout [2].

ESMA also reminded firms established outside the EU that they cannot provide MiCA services to, or solicit, EU clients [2]. Luxembourg’s regulator has added that “reverse solicitation” is not a loophole for third-country firms that actively offer services in the EU [9].

Estonia, the Baltics and Poland

• Estonia. Estonia used the full transitional period. On 1 July 2026 the FIU cancelled the register data for the virtual currency licences used until then, and unauthorised firms may not accept new clients, open new accounts or actively market their services in the European Economic Area [4]. Estonia had 641 such licences in 2021 and 36 at the start of 2026; only one company obtained a standalone CASP authorisation from Finantsinspektsioon by the deadline [5].

• Lithuania. Lithuania closed its window earlier. Operators without a CASP licence by 31 December 2025 could no longer provide crypto-asset services from 1 January 2026 [6].

• Latvia. Latvia chose a six-month transition. Providers had to apply to Latvijas Banka by 30 June 2025 to continue pending a decision, within the EU limit of 1 July 2026 [7].

• Poland. Poland’s Crypto-Assets Market Act, which would designate the KNF as competent authority, has not entered into force, so no Polish authority can currently issue a CASP licence [8]. Polish firms that relied on the national register now need an authorisation from another Member State.

The Options for Affected Firms

A firm that did not obtain a MiCA authorisation generally has three paths: obtain authorisation (or passport an authorisation granted elsewhere in the EU), complete an orderly EU wind-down, or restructure so that its continuing business serves clients outside the EU from a jurisdiction where it can be properly licensed. These paths are not mutually exclusive. A Hong Kong structure does not permit a firm to serve EU clients without MiCA authorisation, and the EU wind-down should be handled by EU counsel in parallel [1][2].

What Hong Kong Offers

Hong Kong regulates virtual asset activity through separate licences, and the right licence depends on what the business actually does:

• Trust and custody arrangements. Acting as trustee of an express trust by way of business in Hong Kong requires a trust or company service provider (“TCSP”) licence from the Companies Registry, which tests whether directors and ultimate owners are fit and proper [12].

• Payments and on/off-ramps. Operating a remittance or money changing service requires a money service operator (“MSO”) licence from the Customs and Excise Department [13].

• Trading platforms. Operating a virtual asset trading platform requires a licence from the Securities and Futures Commission (“SFC”) [10].

• Coming next. The Government has confirmed that a bill introducing licensing regimes for virtual asset dealing and custodian services will be put before the Legislative Council within 2026. The custody regime will not have a deeming arrangement for existing providers [10][11].

Practical Points Before You Restructure

• Map each business line against the Hong Kong licences above before choosing a structure, and keep EU and non-EU client books clearly separated.

• Prepare a full disclosure file. Fit-and-proper reviews in Hong Kong look at directors and ultimate owners [12][13]. A licence that lapsed, was cancelled or was not renewed in the EU should be explained accurately and supported by documents, not omitted.

• Show how EU clients were treated. Records of the EU wind-down, client communications and asset transfers will help demonstrate a sound compliance culture [2].

• Build real substance. A Hong Kong company, suitable directors, AML/CFT policies and banking arrangements need to be in place and consistent with the licence applied for [12][13].

• Plan for the custody regime. Firms that intend to safekeep client private keys should plan around the proposed SFC custodian licence as well as the current TCSP route [10][11].

Conclusion

The end of the MiCA transitional period has removed the national licences on which many Estonian, Baltic and Polish crypto firms relied. Firms that are not authorised under MiCA must stop serving new EU clients and wind down in an orderly way. For businesses with clients outside the EU, Hong Kong offers a licensed path, provided that the structure matches the activities and the regulatory history is disclosed properly. We advise on the Hong Kong side and prepare the relevant applications for you; your EU counsel should handle any EU authorisation or wind-down.

How KTC Can Help

If your firm is restructuring after MiCA, see our Hong Kong options for EU crypto firms, our crypto licensing advisory overview, or request a proposal.

Sources

1. ESMA, Statement on the end of transitional periods under MiCA (17 April 2026)

2. ESMA, Public Statement on unauthorised CASPs as the MiCA transitional period ends (23 June 2026)

3. ESMA, Markets in Crypto-Assets Regulation (MiCA)

4. Finantsinspektsioon, The transitional period for providers of crypto asset services is ending

5. Hacken, Estonia crypto licence after 1 July 2026

6. Legal Nodes, How to get a MiCA CASP licence in Lithuania

7. Licentium, Latvia licensing

8. Identomat, Poland crypto and virtual assets compliance guide

9. CSSF, MiCA: transition period for virtual asset service providers ended on 1 July 2026

10. HKSAR Government press release (24 December 2025)

11. LegCo Panel on Financial Affairs, CB(1)530/2026(06) (1 June 2026)

12. Companies Registry, Guideline on Licensing of Trust or Company Service Providers

13. Customs and Excise Department, Supervision of Money Service Operators