TL;DR
- The grace period is over. MiCA's transitional ("grandfathering") cover for exchanges operating under old national registrations ended in every EEA state by July 1, 2026 at the latest. Since that date, serving European clients without a MiCA CASP authorisation is a breach of EU law — and ESMA has told unauthorised firms to stop onboarding, stop marketing, and wind down.
- The letters are still landing. The freshest documented case is the Netherlands: after the Dutch regulator (AFM) warned in September 2025 that MEXC was serving Dutch users without authorisation, MEXC ran a four-batch offboarding through 2026 — the final batch's deadline passed on October 31, 2026.
- Missing the date is expensive. Under MEXC's stated terms, open futures positions may be closed automatically and unpaid loans settled through collateral sales — with a 5% handling fee on forced loan settlements. Some unsupported assets are converted to USDC whether the holder wants that or not.
- The biggest name missed the licence entirely. Binance withdrew its Greek MiCA application on June 24, 2026 and halted EU services from July 1 — new spot orders, deposits, sign-ups and Earn products stopped; withdrawals stayed open. As of the ESMA register check on October 23, 2026, Binance, MEXC, Bitget and HTX were not on the CASP register.
- The test takes two minutes. ESMA publishes the register of authorised CASPs. If the legal entity holding your account is not on it, the only question left is whether you move on your schedule — or theirs.
What actually changed on July 1
MiCA — the EU's Markets in Crypto-Assets Regulation (Regulation (EU) 2023/1114) — replaced Europe's patchwork of national crypto registrations with a single authorisation: a CASP licence from one national regulator, passportable across all 30 EEA states. Firms already operating legally before December 30, 2024 were allowed to keep serving clients under their old national status while they applied — Article 143(3)'s transitional arrangement, commonly called grandfathering.
Grandfathering was never one deadline. Each member state set its own window: the Netherlands and Poland allowed roughly six months (application cutoffs in June 2025), Germany, Ireland and Austria twelve (to December 30, 2025), and France, Malta, Luxembourg and others the full eighteen months to the EU backstop of July 1, 2026. ESMA confirmed in April 2026 that there would be no extensions. Every window has now closed. A pre-MiCA national registration no longer stands in for authorisation anywhere in the bloc.
That is the mechanical fact underneath every closure letter: an exchange without a CASP licence is not "operating in a grey area." It is in breach, and its regulator knows its name.
The Dutch case: how an offboarding actually runs
The Netherlands is where the process is best documented, because the Dutch AFM moved early. On September 24, 2025, the AFM warned that MEXC was providing crypto services in the Netherlands — custody, trading, order transmission — without the required authorisation, and questioned the transparency of the entity operating the platform.
MEXC's exit unfolded in batches. Its September 29 announcement laid out a four-batch schedule; for the final batch, customers were told to act by October 23, 2026, with restrictions beginning October 24 and completion scheduled for October 31. One caution from the coverage is worth repeating in bold: follow the deadline in your own notice, not a date you read somewhere else — an earlier, broader timetable mentioned later dates, and the batch notice is the one that binds your account.
What happens to customers who miss it is the part of this story that deserves more attention than it gets:
- Derivatives: outstanding futures positions may be closed automatically, at the market, on the exchange's timing.
- Loans: unpaid loans may be settled through collateral sales — and MEXC's terms add a 5% handling fee on borrowed amounts settled this way. On a $10,000 loan, that is $500 before interest and any loss on the collateral sale itself.
- Assets: certain unsupported tokens are converted into USDC; others are settled according to available liquidity — a forced conversion is not the same economic event as selling on your own schedule.
- Remainders: residual assets after the batches are to be transferred to a regulated custodian, with recovery procedures announced separately — your claim survives, but your access becomes paperwork.
MEXC pointed affected Dutch users toward Bybit EU and Kraken as optional destinations. Nothing transfers automatically: no account, no balances, no history. The user does the onboarding, the identity checks, and the transfers — and carries the network-compatibility risk on every withdrawal.
It is not one exchange, and it is not one country
Binance is the scale case. The largest exchange in the world pursued its MiCA licence through Greece for roughly eighteen months, then withdrew the application on June 24, 2026, ahead of an expected rejection. From July 1, 2026 it halted new spot orders, deposits, new sign-ups and Earn/staking products for EU users; withdrawals remained accessible. One industry estimate puts the combined EU user base of the platforms that exited or restricted EEA access at over 25 million accounts (Chainflip) — an estimate, not a census, but the right order of magnitude for what "offboarding" means in practice.
The authorised side of the market is equally concrete, and it is checkable: OKX (Malta, January 2025), Bitstamp and Coinbase (Luxembourg, May and June 2025) and Kraken (Ireland, June 2025) all hold CASP authorisations recorded in ESMA's register. The dividing line in European crypto is no longer big versus small, or cheap versus expensive. It is on the register, or not.
What to do if you hold coins on an offshore exchange
Three moves, in order:
- Identify the entity. The name in your account agreement — not the brand on the app — is what needs to appear on ESMA's MiCA register or your national regulator's list. An authorised European subsidiary does not cover an account held with an offshore entity of the same group.
- Move on your schedule. If the entity is not authorised, withdraw to self-custody or transfer to an authorised provider while you still choose the timing, the network and the price. The wind-down pattern across the industry has been roughly a month between withdrawal-only status and full closure — after that, you are a claimant, not a customer.
- Keep the records. Export trade history, deposits, withdrawals and statements before you lose access. Forced sales and conversions are taxable events in most European jurisdictions, and reconstructing them from a closed account is the worst version of the job.
And a defensive note, because every closure wave produces one: exchanges do not recover funds through social-media messages or "recovery agents." Any approach that arrives unsolicited during an offboarding is a scam until independently proven otherwise.
The bottom line
Europe did not ban crypto. It did something more consequential: it made the licence the product. Exchanges that treated MiCA as paperwork are now discovering that the paperwork was the business — and their customers are discovering it by letter, in batches, on deadlines set by someone else. The register is public, the check takes two minutes, and the cheapest time to make it was before the letter arrived. The second-cheapest time is now.
Sources. ESMA list of MiCA grandfathering periods and ESMA interim MiCA register (register checked October 23, 2026, via feeotter's CASP analysis); Scorechain, "MiCA Grandfathering Explained" (2026); CoinsPress, "MiCA Exchange Rules: What MEXC's Dutch Exit Means for EU Crypto Traders" (October 26, 2026), citing AFM's September 24, 2025 warning and MEXC's September 29 announcement and terms; Decrypt (June 2026) on Binance's Greek application withdrawal, via Tangem and Unicorn Club summaries (October 2026); Chainflip, "MiCA and Binance's EU Exit" (2026) for the affected-account estimate; CASP Tracker authorisation dates via Unicorn Club (October 27, 2026). This article is reporting and analysis, not financial or legal advice.