The MiCA transitional period for pre-existing CASPs operating under national regimes ends 2026-07-01. After that date, full MiCA authorisation is required to continue serving EU residents. The framework has been in full enforcement since December 2024; over €540M in penalties have already been issued.
For BrokerageAtlas operators running a hybrid CFD + CASP stack — covered in the EU dual-licensed CASP + CFD broker archetype synthesis — this is the procedural-cliff event the Phase 3 dispatch flagged in advance.
Penalty exposure for non-compliant CASPs:
- Authorisation denial or revocation.
- Administrative fines up to EUR 5M or 12.5% of annual turnover for natural persons.
- Administrative fines up to EUR 15M or 12.5% of annual turnover for legal persons.
- Public disclosure of violations.
- Potential criminal liability under national AML transposition laws.
KYC implications: MiCA’s KYC framework lives in Articles 68 through 73, setting conduct-of-business rules for CASP-client interactions. CASPs must perform initial identity verification at onboarding and maintain ongoing transaction monitoring, periodic customer re-verification based on risk profiles, and continuous sanctions screening. For operators using Sumsub or ShuftiPro, this maps directly to existing product features; for operators using lower-tier KYC vendors without continuous sanctions screening, the procurement decision needs to be re-opened.
Cross-reference: the recently-announced Sumsub × ComplyAdvantage Mesh integration’s sub-minute sanctions-list propagation is directly material for the MiCA continuous-screening requirement. Operators evaluating KYC stacks for MiCA-track operations after July 2026 should weight Mesh integration as a procurement plus.
What about VARA + DMCC + ADGM operators? This dispatch is EU-CASP-scoped. The non-EU CASP-equivalent regimes (VARA’s Part V Exchange Services Rulebook published 2026-03-31, FSRA Virtual Asset Framework) operate on separate timelines covered in the VARA Part V dispatch.
Source: https://www.zyphe.com/resources/blog/mica-kyc-requirements-in-2026