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On July 1, 2026, the transition period under the Markets in Crypto-Assets (MiCA) Regulation ended across the entire European Union. As of that date, only entities authorized by the competent supervisory authority of a Member State may provide crypto-asset-related services in the EU. In Slovakia, this change took effect earlier, on December 30, 2025. For many existing providers, this is not merely a formality but a disruption to their business operations, involving specific, legally enforceable obligations and a significant risk of penalties.

What has changed, and when did it take effect? 

The legal basis is Regulation (EU) 2023/1114 (MiCA), which replaces national regulations with a uniform framework for the entire EU, including passporting—meaning that once a license is obtained in one Member State, a provider may operate throughout the Union. 

The transitional regime is set forth in Article 143 of MiCA. This article allowed Member States to permit existing providers to continue operating until July 1, 2026, with the option to shorten this period. Slovakia exercised this option and shortened the transitional period to 12 months, i.e., until December 30, 2025. 

What obligations arise for entities without a license? 

From the perspective of the entities concerned, this is the most important part. The end of the transition period is not a passive “expiration” of authorization but is associated with active obligations: 

• a ban on continuing to provide services—this applies to all regulated services under Article 3 of MiCA (custody and administration, platform operation, exchange, transfer, orders, advice, and portfolio management); 
• cessation of client onboarding and notification of clients—as early as September 2025, the NBS called on affected entities to inform clients of the cessation of operations well in advance; 
• return of cryptoassets from custody—the NBS expects that any client cryptoassets held in custody have been returned to clients. 

We specifically note that continuing operations without a license is not merely an administrative offense. The NBS may impose sanctions for unauthorized business operations, and if the elements of the offense are met, it may also constitute the criminal offense of unauthorized business operations under Section 251 of the Criminal Code (No. 300/2005 Coll.), including criminal liability of legal entities.  

What penalties may be imposed? 

A legal entity may be fined up to 5,000,000 EUR or up to 5% of its total annual turnover (Article 111(3) of MiCA) for providing crypto-asset services without a license, and up to twice that amount if the profit obtained can be quantified. 

What do the numbers say? 

The licensing process has set the bar high. Across the EU, out of more than 3,000 initially active providers, approximately 244 companies have obtained a license so far. In Slovakia, six entities hold a license from the National Bank of Slovakia (NBS). By comparison, as of July 1, 2026, the Czech National Bank (ČNB) had reviewed 251 applications and granted licenses to only 11 entities (a success rate of approximately 4.4%). Across the EU, the success rate is below 10%. This is primarily a matter of the quality of the applications, as according to the CNB, a significant portion of the applications were substantively deficient, submitted by entities without a verifiable track record and registered at a virtual address.  

What should consumers do? 

Protection under MiCA applies exclusively to licensed entities. Therefore, we recommend using licensed providers and always verifying their license in the NBS registry of entities. We recommend transferring cryptoassets held with an unlicensed entity to a licensed provider or a self-hosted wallet as soon as possible. 

Do you need legal assistance with the regulatory status of a crypto project? 

If you are unsure whether your business model requires a license under MiCA, whether you have fulfilled the obligations associated with the end of the transition period, or if you are preparing a license application, our attorneys will be happy to assist you with regulatory analysis, preparation of documentation, and communication with the NBS. Contact us.