Three weeks ago, your VASP registration quietly became a much weaker piece of paper than it was on 30 June. If your business is still operating under a national Virtual Asset Service Provider registration and has not converted to a CASP authorization under MiCA, you are no longer inside a grace period. You are past one, and the calendar did not wait for you to notice.
That matters because the terminology question, VASP versus CASP, stopped being academic on 1 July 2026. It is now the difference between a business that can legally serve EU clients and one that cannot, between a banking relationship a European institution will hold and one it is quietly winding down, and between a compliance file that closes cleanly and one a regulator can open an inquiry into.
This guide sets out exactly what changed when the transitional deadline passed, what the two terms actually mean now that only one of them is a live EU authorization, and, honestly, how few businesses in the market have actually finished converting. If your file is one of the majority still mid-transition, the numbers below should tell you how much company you are keeping, and how little time that company actually has left.
Direct Answer
VASP is FATF's global term for a crypto registration; CASP is MiCA's EU authorization, and as of the 1 July 2026 backstop it has fully replaced VASP as the operative EU license. Roughly 280 to 300 of the more than 1,200 previously registered VASPs, about 23 to 25 percent, have converted so far, per ESMA's weekly-updated register.
What Is the Difference Between a VASP and a CASP?
A VASP, Virtual Asset Service Provider, is the term FATF assigned to crypto businesses under Recommendation 15 and its interpretive note on the Travel Rule, Recommendation 16. It is the vocabulary every jurisdiction outside the EU still uses, and it is the term national EU regulators used for their own pre-MiCA crypto registers: an exchange or custodian would register as a VASP with a single member state's authority and operate, in most cases, only within that state's borders.
A CASP, Crypto-Asset Service Provider, is MiCA's own term, created by Regulation (EU) 2023/1114. A CASP authorization is not a registration; it is a full license, assessed against tiered capital requirements, governance and fit-and-proper standards, and AML controls, granted by one national competent authority and then passportable across the entire EU and EEA without a fresh application in each member state.
The practical distinction that actually matters to your business is not the acronym. It is what the authorization lets you do and where. A national VASP registration was always territorial. A CASP authorization is bloc-wide from day one, which is precisely why the EU built MiCA to replace the patchwork rather than sit alongside it.
What to Consider
- Registration versus authorization. A VASP registration was often a lighter-touch filing exercise; a CASP license is a full regulatory authorization with ongoing supervisory obligations attached.
- Territorial versus passportable. Your old VASP registration covered one country. A CASP license, once granted, covers every EU and EEA state you notify.
- Who still uses which term. FATF and non-EU regulators still say VASP. Inside the EU, for live authorization purposes, the term is now CASP, full stop.
- Neither term is a banking guarantee. Being licensed, under either name, gets your file past the first gate. It does not remove the underwriting that follows.
Final Takeaway: If you operate in the EU, stop thinking in VASP terms. The only authorization a European bank, an EU regulator, or a serious counterparty recognizes today is CASP.
What Actually Changed When the MiCA Transitional Deadline Passed?
MiCA began applying to crypto-asset service providers on 30 December 2024, but it built in a transitional window so existing national VASPs would not be switched off overnight. Each member state set its own backstop, and the last of those windows, the EU-wide one, closed on 1 July 2026. Several countries closed earlier: the Netherlands, Finland, Latvia, Hungary, and Slovenia all ended their transitional periods on 30 June 2025, and Sweden followed on 30 September 2025.
Today, three weeks past that final EU-wide backstop, the transitional period is not a live option anywhere in the bloc. A business that was registered as a national VASP and did not either complete a CASP authorization or submit a credible, executable wind-down file is now, as a factual matter, providing crypto-asset services in the EU without authorization. That is not a gray area under MiCA; it is a breach of EU law from 1 July 2026 onward.
What has not changed is the substance of the assessment. National competent authorities are still applying the same capital, governance, and AML bar to every CASP file, whether it arrived in month one of the transitional window or three weeks after the deadline closed. There is no fast-track or leniency for lateness built into the regulation itself.
What to Consider
- Your specific national deadline may have already passed months ago. The Netherlands, Finland, Latvia, Hungary, and Slovenia closed on 30 June 2025; Sweden closed on 30 September 2025. Confirm your home state's actual cut-off, not just the EU-wide backstop.
- A submitted application is not the same as an authorization. Firms that filed before their deadline but have not yet been authorized sit in a different, generally safer position than firms that never filed at all.
- "Transitional" no longer exists as a status after 1 July 2026. There is no extended grace period; the European Commission's current review activity (see below) is a policy conversation about the future, not a retroactive extension for today.
- A slow enforcement pace is not the same as a legal right to keep operating. The gap between deadline and enforcement action is not compliance.
Final Takeaway: Check your national deadline, not the EU headline date. If you are still mid-file today, you need to know exactly how late you are, in your specific member state, before you decide what to do next.
How Many Crypto Businesses Have Actually Converted From VASP to CASP?
This is the number that should concern anyone who assumed the market had quietly sorted itself out by now. Of the more than 1,200 businesses previously registered as VASPs across the EU's national regimes, only roughly 280 to 300 hold a granted CASP authorization as of late July 2026. That is a conversion rate of only about 23 to 25 percent, three full weeks after the transitional backstop closed.
That figure is not a single fixed data point. ESMA maintains a public register of authorized CASPs that updates weekly, and the count has been climbing steadily through 2026 rather than arriving all at once: roughly 210 authorizations by May 2026, around 280 by 9 July, approximately 293 by 17 July, and sitting in the 291-to-297 range as of 21 July 2026. Treat any number here as a snapshot from a moving register, not a permanent figure.
| Date (2026) | Approx. authorized CASPs | Approx. conversion rate |
|---|---|---|
| May | ~210 | ~17% |
| 9 July | ~280 | ~23% |
| 17 July | ~293 | ~24% |
| 21 July | ~291–297 | ~24–25% |
The math behind that rate is what makes it the single most important fact in this entire cluster. If roughly 1,200 businesses were registered as VASPs before MiCA's transitional periods began closing, and only about a quarter of them have been authorized as CASPs, then somewhere between 900 and 950 previously registered crypto businesses are, right now, operating without a valid EU authorization, mid-application, or have quietly exited the EU market altogether.
Example
A composite mid-sized exchange, previously VASP-registered in a Baltic state, filed its full CASP application in January 2026, five months ahead of its national deadline. Its national competent authority's assessment ran past the statutory review window twice, requesting additional AML documentation each time, and the file was still pending when the EU-wide backstop closed on 1 July. The business was, technically, unauthorized for three weeks before its CASP license was finally granted in late July, despite having filed early and in good faith.
What to Consider
- A quarter converted does not mean three-quarters are safe. Most of the remaining roughly 900 businesses are either mid-application, have exited, or are operating unauthorized. None of those three positions is comfortable.
- Filing early is not the same as being authorized early. The example above filed five months ahead of deadline and was still caught by the assessment backlog.
- The register moves weekly; your assumption about your own status might already be stale. Confirm your file's actual status with your national competent authority rather than assuming a submission counts as coverage.
- A low conversion rate industry-wide is a market signal, not just a regulatory one. Banks and counterparties reading this same data will price unauthorized exposure into every relationship you hold.
Final Takeaway: Roughly one in four previously registered VASPs has actually finished converting. If you have not confirmed which side of that line your business sits on this week, that is the first thing to settle, before anything else in this guide.
Which EU Jurisdictions Have Authorized the Most CASPs?
Germany currently leads the EU by number of granted CASP authorizations, holding roughly 55 to 59, close to a fifth of the entire bloc's total. A significant share of Germany's count is made up of traditional banks converting existing permissions rather than crypto-native start-ups filing fresh applications, which says something about who is moving fastest: institutions that already had a supervisory relationship with BaFin before MiCA existed.
France and the Netherlands follow, each with authorizations in the high teens to high twenties, and Malta, Cyprus, and Ireland round out the group most often cited as the current top tier. None of these rankings are static; the ESMA register updates weekly, and month-to-month movement between these jurisdictions is normal rather than exceptional.
| Jurisdiction | Approx. CASPs authorized | Notable pattern |
|---|---|---|
| Germany | ~55–59 | Roughly a fifth of the EU total; many are converting banks, not new entrants |
| France | ~19–30 | Established crypto-asset market from the pre-MiCA PSAN regime |
| Netherlands | ~26–27 | Early closer of its own transitional window (30 June 2025) |
| Malta | ~15–22 | Deep pre-MiCA crypto licensing track record |
| Cyprus | ~12–20 | Strong for brokerage and advisory firms transitioning to CASP |
| Ireland | ~12 | Smaller volume, established financial-services infrastructure |
One country conspicuously absent from that top tier by current authorization count is Lithuania, despite its reputation as the EU's fintech-friendly fast lane. That reputation is not baseless: Lithuania closed its own national VASP-to-CASP deadline on 1 January 2026, six months ahead of the EU-wide backstop, and it keeps new CASP applications open year-round rather than running a single filing window. But being fast to close the old regime and being fast to grant the new license are two different things.
A compliance firm working the Lithuanian market reported helping more than 20 applicants prepare CASP files by mid-2025, with only a single approval granted at that point. That is a useful, if uncomfortable, data point: it suggests the Bank of Lithuania's substantive review is considerably more rigorous in practice than the jurisdiction's fintech-friendly marketing implies, even though its process and cost remain genuinely competitive once a file is complete.
What to Consider
- Authorization count is not the same as ease of authorization. Germany's high count includes converting banks with existing supervisory relationships, not a signal that BaFin's bar is low.
- Lithuania's fast entry point is real, but so is its review rigor. Treat "fintech-friendly" as a claim about process speed and cost, not about the odds of a first-time approval.
- Jurisdiction choice shapes your banking outcome, not just your license. A CASP authorized in one member state can passport EU-wide, but the home regulator's reputation still colors how counterparties read your file.
- These figures move weekly. Confirm current standings against ESMA's own register before making a jurisdiction decision on the strength of any single month's numbers, including this guide's.
Final Takeaway: Do not choose a jurisdiction on reputation alone. Match your service mix, budget, and target market against each regulator's actual current review behavior, not last year's marketing.
Is "VASP" Completely Dead as a Term Now?
Inside the EU, for the purpose of ongoing authorization, yes. There is no live "VASP" registration category left standing anywhere in the EU or EEA for a business that wants to keep operating past the transitional backstop. CASP has fully superseded it as the operative authorization, and any national VASP register that still technically exists on paper is a historical artifact of the regime MiCA replaced, not a route to legal operation.
Outside the EU, the term is very much alive. FATF built Recommendation 15 and its Travel Rule interpretive note, Recommendation 16, around the VASP concept, and every jurisdiction implementing FATF standards, from Singapore to the UAE to the United States' own state-and-federal patchwork, still uses "VASP" as its working vocabulary. If your business also serves non-EU markets, you will keep using the term there regardless of what happens inside the EU.
There are two genuine nuances worth naming rather than glossing over. France's old national PSAN regime (Prestataire de Services sur Actifs Numériques) is in the process of being folded into the CASP framework rather than simply switched off, which has created its own local transitional mechanics distinct from the EU-wide timeline. And outside the EU entirely, El Salvador has coined its own term, DASP (Digital Asset Service Provider), which is neither VASP nor CASP and should not be confused with either.
Reality Check
A CASP license does not automatically mean "bankable" any more than a VASP registration ever did. Banks and EMIs still run their own underwriting on top of any authorization, and a business that treats the license as the finish line, rather than the credential that gets it into the room, is usually the one surprised when the banking conversation turns out to be a separate, harder gate.
What to Consider
- "VASP" in EU marketing materials today is often stale. If a provider or partner still advertises a "VASP license" as a live EU product, treat that as a red flag about how current their compliance knowledge actually is.
- Keep both vocabularies if you operate globally. Use CASP for EU-facing regulatory and banking conversations; VASP remains correct and expected for FATF-aligned non-EU jurisdictions.
- France's PSAN-to-CASP folding is its own local mechanic. If you hold or held a French PSAN registration, confirm your specific transitional path with the AMF rather than assuming the generic EU timeline applies unmodified.
- Don't let a licensed status substitute for a banking plan. Line up your fiat rails in parallel with authorization, not after it.
Final Takeaway: Use CASP for every EU conversation from today onward. VASP survives only as FATF's global vocabulary and as a description of the regime MiCA replaced.
What Should a Legacy VASP Do Right Now?
If your business is one of the roughly three-quarters still without a granted CASP authorization, the honest starting point is establishing exactly where your specific file sits: authorized, mid-application with a confirmed submission date, or genuinely unauthorized with nothing filed. Each of those three positions calls for a different immediate response, and conflating them is the single most common mistake at this stage.
A mid-application file needs an honest read on realistic timing. MiCA's statutory clock gives the national competent authority roughly 25 working days to confirm an application is complete, followed by a further assessment window commonly cited at up to 40 working days from a complete file, often longer in practice. Real end-to-end timelines, preparation included, commonly run four to twelve months once local substance, capital, and file quality are factored in. If your file is not yet submitted, that timeline starts from today, not from 1 July.
The wind-down and reverse-solicitation questions, what a genuinely unauthorized business should do next, and whether serving EU clients who approach unprompted is a viable workaround, deserve a fuller, honest answer than a single paragraph here can give them justice. Treat any shortcut pitched around this deadline with real skepticism until you have seen its specific regulatory basis in writing, not just heard it asserted.
What to Consider
- Confirm your exact file status this week, not your general impression of where things stand. Get it from your national competent authority or your counsel, in writing.
- If you are mid-application, push for a realistic timeline, not a hopeful one; four to twelve months is the honest range once local substance and capital are accounted for.
- If you have nothing filed, do not assume reverse solicitation covers you. ESMA interprets it narrowly, and it is not a general workaround for missing the deadline.
- Consider whether an EU-authorized affiliate structure fits your model. This is genuine structuring work, best done with advice rather than assumption.
Final Takeaway: This week, get a written answer on where your file actually stands. Everything else, wind-down, structuring, a fresh application, follows from that one fact.
Conclusion
VASP and CASP were never just two names for the same thing, and three weeks past the 1 July 2026 backstop, the gap between them has become the whole story. CASP is now the only live EU authorization; VASP survives as FATF's global vocabulary and as a description of the regime MiCA replaced. Roughly a quarter of the market has actually finished converting, which means most of the businesses reading this guide are still exposed in one of three ways: mid-application, unauthorized, or quietly winding down.
None of those three positions improves by waiting. A mid-application file needs a realistic timeline and pressure to keep it moving. An unauthorized file needs an honest assessment of wind-down obligations and, where relevant, structuring options, not a hopeful bet on reverse solicitation. And a business that has already converted should not assume the CASP license itself closes the banking conversation; it opens it.
One more piece of current-events context worth watching: the European Commission opened a targeted review consultation on MiCA on 20 May 2026, open for comment until 31 August 2026. Whether the roughly 25 percent conversion rate factored into that timing is not confirmed policy, but it is a plausible part of the backdrop, and it means the rules around this exact transition could still move again before the year is out.
How BankMyCapital Helps
We are not a bank, an EMI, or a law firm, and nothing here is legal advice. What we do is assess where your specific file actually sits against the MiCA timeline, help you read the realistic path from your current status to a granted CASP authorization or a properly executed wind-down, and, where a business genuinely needs it, work through structuring questions like an EU-authorized affiliate model as one option among several, honestly framed as informed industry practice rather than confirmed policy. Full detail on the license itself, its capital tiers, and its jurisdiction picture lives on our CASP license page, part of the wider crypto licensing practice.