End of the MiCA Transition Period: VASP Obligations to the GIIF and Reporting for the Second Quarter of 2026

The turn of June and July 2026 marks a time of an absolute regulatory test for the crypto-assets sector. The expiration of the transitional period provided for under the MiCA Regulation drastically changes the legal standing of VASPs (Virtual Asset Service Providers).

For entities operating so far without an EU authorization, this implies the necessity to immediately cease providing services, unless they have obtained the status of a licensed CASP (Crypto-Asset Service Provider).

Importantly, on June 23, 2026, ESMA published an official Public Statement. This document specifies a rigid framework for the orderly wind-down procedure to be followed by unauthorized entities.

VASP Quarterly Report to the GIIF for the Second Quarter of 2026 – Who Is Required to File It?

In a statement dated June 26, 2026, the General Inspector of Financial Information (GIIF) explicitly reminded entities entered into the VASP register of their mandatory reporting obligations:

• Standard Obligation. These entities are under a strict obligation to submit their quarterly report for the second quarter (Q2) of 2026.
• The Exception. If an institution ceased providing services before the end of Q2 2026, its legal obligation is to submit official feedback to the GIIF instead of the standard quarterly report.

If you operate as a VASP or are preparing to obtain a CASP license, you should verify immediately whether all obligations to the GIIF have been properly fulfilled.

Our team can help you assess your regulatory situation, prepare your report for the second quarter of 2026, and safely wind down your operations in accordance with MiCA and ESMA guidelines. Contact us to discuss the obligations applicable to your business and minimize the risk of administrative sanctions.