The CNMV has published a Q&A document on the implementation of MiCA, shortening the transition period to December 30, 2025, forcing crypto asset platforms to comply or leave the Spanish market.
The Spanish National Securities Regulator (CNMV) has just published a specialized Q&A document clarifying how the European Union's Cryptocurrency Market Regulation (MiCA) is being applied in practice. This move places Spain among the pioneering EU member states, like Italy, in proactively utilizing flexible mechanisms during the transition period instead of allowing legal uncertainty to persist.
This document guides crypto asset service providers (CASPs) on key questions related to licensing in Spain, while clarifying how national procedures are integrated with MiCA. It covers the scope of regulation, how MiCA interacts with existing national regulations, and the licensing and notification process established by the CNMV.
The Q&A section also explains how to handle notifications related to licensing and cross-border operations during the transition period, emphasizing that businesses must strictly adhere to deadlines.
The transition period has been shortened.
According to MiCA, member states can allow existing providers to continue operating during a transitional period limited to July 1, 2026, or until a license is granted or denied, whichever comes first. However, Spain has chosen to shorten this period, ending on December 30, 2025.
Organizations benefiting from the transitional mechanism must obtain a MiCA license before this date if they wish to continue providing crypto asset services in Spain. Companies that do not meet the requirements will no longer be permitted to operate and must be prepared to adjust their business model or cease operations, depending on the outcome of the licensing process. This decision creates significant time pressure for crypto asset platforms operating in the Spanish market.
Alongside the guidance document, the CNMV also issued new criteria on how MiCA applies to funds, Investment Vehicles , and entities regulated under MiFID II. The agency also updated guidance on when investment-related influencers are considered to be engaging in client solicitation activities. The CNMV asserts that these measures are part of a broader effort to enhance investor protection once MiCA takes full effect.
Spain's move follows similar steps in Italy, where the CONSOB regulatory authority has set a deadline of December 30, 2025, for existing digital asset service providers (VASPs) to submit applications for MiCA-standard licenses or withdraw from the market. Allowance to operate during the transition period applies only to entities that have submitted applications, and in any case no later than June 30, 2026.
