With the 1 July 2026 deadline fast approaching, transitioning from the DASP regime to CASP authorisation under MiCA is no longer just a matter of regulatory strategy; it has become an operational necessity. Between AML/CTF compliance requirements and the threat of criminal penalties for providing services without authorisation, this analysis examines the risks of this transition and the measures that must be implemented to manage them.

Last week, the French Financial Markets Authority (AMF) issued a reminder regarding a critical deadline. Digital asset service providers (DASPs) that do not hold a CASP authorisation (the new European authorisation) will no longer be permitted to operate from France following the end of the transitional period on 1 July 2026. This announcement carries significant implications for the firms involved, as well as for the broader market and investors.

Operational risk for crypto participants

As of 1 July 2026, any crypto-asset service provided without the required CASP authorisation will be classified as an illegal practice. In such cases, the DASP may be held liable, and its directors could face criminal prosecution. For the entities concerned, preparing for the cessation of activities is becoming a pressing matter, if not an urgent one, considering the timeframes necessary to ensure an orderly wind-down or to successfully obtain a CASP authorisation.

Ending operations is a complex task for a supervised entity which must guarantee compliance with its regulatory obligations, such as AML/CTF , the protection of client rights , complaints handling , and data retention for five years (including post-cessation). These risks are exacerbated when the entity faces financial difficulties.

Regarding the custody and administration of crypto-assets, DASPs must prepare for restitution to their clients. For dormant accounts, there is no automatic escrow mechanism with the Caisse des Dépôts et Consignations (unlike for payment accounts). Consequently, the DASP should anticipate entrusting the crypto-assets to a CASP. This operation must be meticulously managed in relation to clients, as well as the AMF, considering regulatory and cyber risks (such as data breaches). Specifically, transferring KYC/KYB records presents numerous challenges.

Towards a more concentrated market

Out of the approximately 120 registered DASPs:

• 25% have obtained or are currently obtaining their CASP authorisation.

• 25% have announced they are unable or unwilling to seek CASP authorisation.

• 25% have made no declaration and are currently being contacted by the regulator.

• The remaining 25% are subsidiaries of foreign groups that no longer need to operate from France (passporting).

As a result, the market is moving towards a group of around thirty participants in France. It should be noted that the passporting mechanism allows for the provision of services across the entire European Union relatively easily.

What about investors?

A number of investors will be required to change their service provider to buy, sell, or ensure the custody of their crypto-assets. It is recommended to anticipate this deadline to avoid potential account closures or the transfer of crypto-assets to another CASP, depending on their provider’s situation.