Concept
MiCA introduced a unified regime for crypto business in the EU: instead of national VASP status (an FATF term), there is now CASP (crypto-asset service provider) authorisation. Since 30 December 2024, applications under the old VASP regime are no longer accepted; the transition to CASP is underway. White-label under a CASP licence means operating under the authorisation of an established provider: a service launches a branded exchange, wallet or custody without obtaining its own MiCA licence, while the authorised CASP bears the regulatory obligations.
The value lies in passporting: a single CASP authorisation in any EU country grants the right to operate in all 27. This is the same licence-rental model as in payments and funds—see embedded finance.
🍓 Passporting is only available with full CASP authorisation. A national "transitional" status is valid only in its own country and does not confer passporting rights—this is easy to overlook when choosing a white-label partner.
How it works
An authorised CASP holds the MiCA licence and is responsible for governance, capital, custody of client assets, prevention of abuse and AML. The white-label partner gains access to the infrastructure and licence: brand, client interface, distribution. The list of CASP services—custody, exchange, execution, placement, advice, transfer of crypto-assets—determines what can be offered under that licence.
Deadlines: hard deadline of 1 July 2026
Grandfathering: those who provided crypto services under national law before 30 December 2024 may continue until 1 July 2026 or until MiCA authorisation is granted or refused. 1 July 2026 is a hard deadline: all national transitional periods expire, and without CASP authorisation (or a timely application) regulated services in the EU must cease. No extensions are provided.
An important detail: Member States chose different transition lengths—18, 12 or 6 months—and in most countries the key application deadline has already passed in 2025. Therefore, white-label through a provider with full CASP authorisation has become the fastest legal route into the EU for many.
What is needed
- Route. Either operate under an established CASP's authorisation (white-label), or obtain your own MiCA authorisation.
- Foundation. A legal entity in the EU, AML/KYC package, established custody and monitoring processes.
- Partner verification. The provider's status is checked against the register of authorised CASPs maintained by ESMA: national VASP status is not equivalent to CASP authorisation and does not confer passporting rights.
⚙️ Before launching under a third-party licence, make sure your partner has CASP authorisation (not "pending" and not old VASP) and that the services you need are within its scope. Passporting and legality depend on this.
Compliance
Under MiCA: requirements for governance and capital, segregation and protection of client assets, rules against market abuse, complaints handling and disclosure. Operational resilience is regulated by DORA (ICT risks of third parties, in force since 17 January 2025). AML/CFT follows the general EU regime. Responsibility for compliance remains with the authorised CASP.
Applicable regulation
MiCA (Regulation (EU) 2023/1114) and ESMA technical standards set out the CASP regime and the transition from VASP (ESMA, MiCA). Operations—DORA. The general principle "responsibility cannot be outsourced" and related trends—in regulatory perimeter. Related licence-rental models: payments—payment agents in the EU, banking—BaaS and sponsor banks, crypto jurisdictions in general—crypto-friendly jurisdictions.
Q/A
Can you operate in the EU under old VASP status after 1 July 2026. No: transitional periods expire. CASP authorisation or a timely application is required, otherwise services must cease.
Does white-label confer EU passporting. Yes, if the partner is a fully authorised CASP. National transitional status does not confer passporting.
How does CASP differ from VASP. VASP was a national AML registration with no cross-border effect; CASP is a MiCA financial authorisation with passporting across the entire EU.
This material is prepared as an expert overview and does not constitute individual legal advice.
FAQ
Can you operate in the EU under old VASP status after 1 July 2026. No: transitional periods expire. CASP authorisation or a timely application is required, otherwise services must cease.
Does white-label confer EU passporting. Yes, if the partner is a fully authorised CASP. National transitional status does not confer passporting. How does CASP differ from VASP. VASP was a national AML registration with no cross-border effect; CASP is a MiCA financial authorisation with passporting across the entire EU. This material is prepared as an expert overview and does not constitute individual legal advice.
Key factual claims
- The value lies in passporting: a single CASP authorisation in any EU country grants the right to operate in all 27.
- Grandfathering: those who provided crypto services under national law before 30 December 2024 may continue until 1 July 2026 or until MiCA authorisation is granted or refused.
- An important detail: Member States chose different transition lengths—18, 12 or 6 months—and in most countries the key application deadline has already passed in 2025.
- MiCA (Regulation (EU) 2023/1114) and ESMA technical standards set out the CASP regime and the transition from VASP (ESMA, MiCA).