On 1 July 2026 the transitional period for the EU’s Markets in Crypto-Assets regulation, MiCA, comes to an end. From that day, any firm providing crypto-asset services to clients in the EU without a MiCA licence is in breach of EU law and must stop.1 The UK sits outside the EU and is building its own framework under the FCA, so the deadline does not bind UK firms at home. It would be a mistake, though, to read it as someone else’s problem.
Where an EU rule reaches across the border
MiCA does not stop at the Channel as cleanly as it looks. A firm based outside the EU may serve EU clients only when the client approaches it at their own exclusive initiative, with no marketing or solicitation from the firm. ESMA has been explicit that this reverse-solicitation exemption is narrow, and that “solicitation” is read broadly enough to capture advertising and general brand-building.2 In practice, any UK provider that markets to EU clients needs MiCA authorisation, usually by establishing an EU subsidiary and licensing it there, the route several large exchanges have already taken.2
So the relevant question for a UK firm is not its postcode but its client base. A UK manager with European clients, or with an EU subsidiary or booking entity, is inside MiCA’s perimeter for that activity regardless of Brexit. For UK advisers recommending such managers, the licence question travels with the client.
The reputation and standards effect
There is a softer reach too. MiCA is fast becoming the European reference standard for how a crypto provider should be run, and the FCA’s own emerging regime is being built in the same regulatory climate. Clients, allocators and counterparties increasingly use MiCA as shorthand for “run to an institutional bar.” A provider that already meets it signals a seriousness that carries weight in London as much as in Frankfurt, well before any UK rule formally requires it.
What a MiCA licence does, and what it does not
Precision matters, because MiCA does not cover all of crypto. It applies to crypto-asset services such as custody, exchange, and the management of and advice on crypto-assets.2 It does not apply to instruments already treated as financial instruments under EU law; most crypto exchange-traded products, for example, sit under MiFID II rather than MiCA.2 A MiCA licence therefore says nothing about returns or investment safety. It certifies regulatory standing: governance, capital, custody, conflicts of interest, and disclosure. It is a statement about the counterparty, not the asset.
Where CoinShares sits
This is where early preparation shows. CoinShares Asset Management, the group’s French entity, became the first regulated asset manager in continental Europe to receive MiCA authorisation, granted by the AMF in July 2025, a full year before the deadline. It holds that authorisation alongside existing MiFID and AIFM permissions, and has passported its services across eight EU markets. For a UK adviser whose clients have European exposure, or who simply values a provider already operating to the EU’s standard, that is reassurance which can be checked rather than taken on trust.
What this means for your due diligence
The deadline is an EU event, but it hands UK advisers a useful test. Ask any crypto provider you consider whether they are MiCA-authorised, and where you can verify it. If your clients touch the EU, the rule touches you; and even where it does not, the firms that cleared the EU’s bar early are the ones that took the standard seriously first.
1 Autorité des Marchés Financiers (AMF), “The AMF reminds Digital Asset Service Providers that the transitional period allowing them to continue providing crypto-asset services in France without MiCA authorisation ends on 1 July 2026”, 2026.
2 European Securities and Markets Authority (ESMA), “Guidelines on reverse solicitation under MiCA”, February 2025, and “Markets in Crypto-Assets Regulation (MiCA)” overview page (scope and cross-border provision).