MiCA 'Application in progress' enquiry20 Sep 2025 09:34
Hopefully we get some answers........Application in progress is opaque to me. July 2026 could be a more realistic time frame imo.
https://x.com/ChaebolChris/status/1969309241191096642
In your financial report you state that MiCA approval is due H2, you also state Application in progress? what does that mean ? are you still completing the application process ie compliant and aligning with MiCA protocols or is the MiCA license application filed and awaiting regulatory approval ? Application in progress is very vague.
MiCA’s regulatory language: MiCA and ESMA’s implementing standards (e.g., ESMA’s Final Report on CASP authorization, ESMA35-43-4683) use precise terms like “application for authorisation,” “notification,” “assessment period,” or “grandfathering” to describe stages of the Crypto-Asset Service Provider (CASP) licensing process. “Application in progress” does not appear in the regulation or official guidance.
“Application in Progress” for VASPs Under MiCA
Not a legal term: As with general MiCA licensing, “application in progress” is not a defined legal term in MiCA or ESMA’s guidelines for VASPs transitioning to CASP status. It’s an informal phrase that could mean:Preparing an application: The firm is working on compliance (e.g., AML/CTF policies, capital requirements, or governance structures) to apply for CASP authorization but hasn’t submitted yet.
Application filed: The firm has submitted a CASP application to a National Competent Authority (NCA), like the FCA in the UK (noting the UK aligns with MiCA-like rules post-Brexit), and is awaiting review.
Transitional provisions (MiCA Article 143): VASPs registered under pre-MiCA national laws (e.g., AMLD5 in the EU or FCA’s crypto register in the UK) can operate during a transitional period (until July 1, 2026, in most EU jurisdictions) while applying for full CASP authorization. A VASP claiming “application in progress” might be signaling they’re leveraging this period, but it doesn’t confirm whether they’ve filed or are still preparing.
Regulatory ambiguity: Since NCAs (e.g., FCA, AMF in France) and ESMA don’t disclose pending applications (as you correctly noted, due to sensitive commercial data), “application in progress” is a self-reported claim. It’s not verifiable publicly until authorization is granted and listed in ESMA’s CASP register or the FCA’s Financial Services Register.
Can you kindly elaborate on the non legal term of 'Application in progress' you have with your MiCA license. As this kind of suggests you are still completing the legal and compliance framework to actually apply.... Thank you.
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