Spain’s transition to the European Union’s crypto licensing regime ended on 1 July 2026, as FinanceFeeds reported before the cutoff. The date was not extended: from 1 July, the CNMV says only providers authorised in Spain or another European jurisdiction may offer regulated crypto-asset services to Spanish users.
Eight weeks later, the result is less binary than a mass shutdown. The number of authorised providers has risen, firms licensed elsewhere have entered Spain through MiCA passporting, and large unlicensed platforms have restricted services while keeping withdrawal routes open. Most of the more than 1,200 firms registered under the EU’s earlier national regimes still have not converted, but that does not mean every one of them is quietly continuing normal business.
What the CNMV Said, and What It Refused
CNMV Chair Carlos San Basilio said that “there will be no exceptions or extensions” to the transition period. The scope of that statement was the permission that had allowed legacy firms to continue operating without MiCA authorisation, not the time customers could be given to retrieve assets during an orderly exit.
Under the transition rule, a qualifying provider could continue until 1 July 2026 or until its application was granted or refused, whichever happened first. San Basilio said the regulator was in contact with firms that had not received approval and was focused on how they would transfer client assets and cash while preserving customer rights. The CNMV’s current guidance repeats that providers without Spanish or EEA authorisation cannot operate in Spain. A review of the CNMV’s public sanctions register through 26 August found no published penalty explicitly identified as a post-cutoff MiCA case against a legacy CASP.
Where the Numbers Stand Now
At the cutoff, roughly 230 MiCA licences had been issued across the EU, according to GNCrypto’s count. Compared with more than 1,200 legacy virtual-asset service providers, that supported the finding that more than 80% had not converted by 1 July.
That percentage should not be presented as current. The ESMA register dated 21 August contains 330 unique legal entities, including two with recorded authorisation end dates, leaving 328 active entries. Fifteen active entities have Spain as their home state. The file combines standard CASP authorisations with notifications by banks and other regulated financial firms, so it is not a count of 328 newly licensed crypto exchanges. Even a generous comparison with the 1,200-plus legacy population, however, leaves most firms unconverted. The register has continued to grow since the cutoff, as seen when ESMA added 37 records immediately after the transition and in FinanceFeeds’ later review of duplicate and notification records.
What a Compliant Wind-Down Looks Like
The cutoff did not permit an unauthorised firm to keep trading while an application remained unresolved. ESMA’s wind-down statement, republished by the CNMV, required such firms to stop onboarding and advertising to EU clients immediately. Services were to be limited to selling or transferring crypto-assets, reallocating assets and closing positions. Custody could continue only for the time strictly necessary to complete the exit.
Providers also had to communicate clear exit plans repeatedly, telling clients when and how they could sell, transfer, reallocate or close positions. That is why continued account access after 1 July is not, on its own, evidence that a platform kept serving users illegally. A withdrawal-only account is part of the expected wind-down. New orders, deposits or client acquisition would raise a different question.
The Passporting Escape Hatch, and Who Used It
MiCA replaced separate national registrations with a home-state licence that can be passported across the EEA. ESMA’s 21 August file shows at least 114 active entities listing Spain among their service countries, far more than the 15 for which Spain is the home state. The group includes Bitpanda from Austria, OKX and Crypto.com’s Foris DAX entity from Malta, Bybit from Austria and Coinbase from Luxembourg.
This was not an extension for Spanish legacy registrations. It was a different legal route based on authorisation in another member state and notification of cross-border services. OKX’s Malta-based passporting illustrates how one approval can support service across the EEA without a separate Spanish licence.
What Spanish Users Lost Access To
Binance provides the clearest practical example. After missing the deadline, the platform stopped taking new EU registrations and restricted services for customers in Spain and other EU markets. Users could still access assets and withdraw them, but the wind-down removed normal access to new trading and other services rather than instantly freezing every account.
The migration did not flow entirely to licensed exchanges. Binance’s chief executive later said 70% of EU withdrawals went to self-custody wallets, a company-supplied figure that has not been independently verified. The supported conclusion eight weeks after Spain’s cutoff is therefore narrower: Spanish users lost access to normal service at prominent unlicensed providers, while authorised domestic and passported firms remained available. The licensing gap is still large, but the public record points to restricted exits and market migration, not proof that the majority quietly carried on as before.
