MiCA changes in 2026 and what investors should already consider this year

The crypto-asset market is currently undergoing a significant phase of regulatory change that will have a direct impact in the near future on anyone investing in this sector or relying on the infrastructure of crypto-asset service providers.

The transitional period ends on 31 December 2025. From 1 January 2026, crypto-asset service providers will be allowed to operate within the European Union only if they hold a crypto-asset service provider licence issued by the Bank of Lithuania in accordance with the MiCA framework. MiCA (the Markets in Crypto-Assets Regulation) is an EU regulation adopted to establish a harmonised and clearly defined regulatory framework for the crypto-asset market across the European Union.

Crypto-asset service providers will be able to operate lawfully only if they obtain a licence under MiCA either in Lithuania or in another EU Member State. This means that crypto-asset service providers will be subject to a uniform licensing regime and consistent operational requirements, regardless of the Member State in which they are established. For investors, this brings greater regulatory clarity but also introduces a new responsibility: ensuring that the service provider they use is adequately preparing for these changes.

This requirement is not a technicality. It directly affects service availability, investment security and the future of the companies in which investors may be placing their capital. If a service provider does not apply for a licence or fails to obtain it in time, it will simply no longer be permitted to continue its activities. As a result, investors may face unexpected service restrictions, temporary asset transfers or access disruptions, and in some cases may need to urgently seek alternative providers.

From an investor’s perspective, licensing also has a positive dimension. A MiCA licence signifies a higher operational standard, including stronger risk management, clearer governance structures, stricter safeguards for client assets and greater transparency. These measures are expected to reduce uncertainty and enhance market credibility, as providers unable to meet higher compliance and transparency requirements will exit the market.

The Bank of Lithuania has indicated that investors should not wait until these changes formally take effect. Investors are encouraged to already assess whether their service provider intends to apply for a licence, whether it has a business continuity plan in place, and whether its internal processes align with the new regulatory requirements. Having this information in advance allows investors to evaluate potential next steps and determine whether their current provider is suitable for long-term cooperation in the new regulatory environment.

To make informed decisions, investors are advised to promptly review their service providers. The relevant information is publicly available:

Data from the Bank of Lithuania on crypto-asset service providers licensed in Lithuania:
https://www.lb.lt/lt/finansu-rinku-dalyviai?market=3&subject=3

List of crypto-asset companies licensed in other EU Member States and providing services in Lithuania without local establishment:
https://www.lb.lt/lt/finansu-rinku-dalyviai?ff=1&market=3&subject%5B%5D=3&business_form%5B%5D=133

Successful investors consistently assess not only market opportunities but also systemic risks. Today, one of the most significant risks is whether a service provider will remain operational after the end of 2025. The sooner this is clarified, the easier it will be to plan future steps and ensure that investments are not adversely affected by unforeseen regulatory constraints.