Skip to content
Login

MiCA's Grace Period Is Over: What Crypto Businesses Now Need to Show Their Bank

2026-10-20

A row of European Union flags on tall poles along a sunny city street, with a tram and green trees behind them

The Deadline Has Passed

For a year and a half, plenty of crypto businesses in Europe operated in a space that was legal but temporary. The Markets in Crypto-Assets Regulation (MiCA) began applying to service providers on 30 December 2024, yet firms already working under national rules were allowed to carry on while they applied for a MiCA licence. Each member state picked the length of that grace period. Some kept it short (the Netherlands gave six months). The longest possible one ran until 1 July 2026.

That date has come and gone, and the window is now closed across the EU. A company providing crypto-asset services to EU clients needs MiCA authorisation. Without it, it shouldn't be providing them.

If you run an exchange, a wallet, an on/off-ramp or a payment business that touches crypto, no other rule this year changes the conversation with your bank as much.

What ESMA Expects From Firms Without a Licence

On 23 June 2026 the European Securities and Markets Authority published a statement on what unauthorised providers must do once the deadline passes. Stripped down, it says they should:

ESMA also repeated that firms based outside the EU can't provide MiCA services to EU clients, business clients included. The only exception is the narrow case where a client comes to them entirely on its own initiative.

There is nothing ambiguous here. An unlicensed crypto business still taking on EU customers is in breach of EU law, and no bank or payment provider wants to be the one moving its money.

Why Your Bank Cares About Your Licence

Your bank isn't your regulator. It is, however, responsible for knowing who its clients are and what they do, and for not facilitating activity it shouldn't.

Until July, "our application is pending under the transitional regime" was a perfectly reasonable answer. Today the same sentence can mean two very different things. Either the firm has stopped serving EU clients while it waits, or it hasn't. A compliance team has to work out which, and it will ask.

That's why authorisation is now the first topic for crypto businesses opening an account, and why it comes back at periodic reviews of accounts that were opened years ago.

What You'll Probably Be Asked For

Every provider has its own checklist, but the questions tend to fall into a few groups.

People tend to underestimate that last point. An account that pays staff and rent carries a very different risk from one that collects client money for an exchange, and the provider needs to know which of the two it's being asked to open. Once the account is live, payments that don't match that picture are what usually trigger questions about where money came from.

Not Every Crypto Business Is a CASP

A lot of companies that touch crypto aren't crypto-asset service providers. A software house that builds wallet technology, a merchant taking payments through a licensed processor, a firm holding some crypto on its balance sheet: none of these typically provides MiCA services itself.

If that's you, say so in the first message and explain what role crypto plays in the business. Otherwise a compliance analyst reading the word "crypto" on an application may reasonably start from the strictest interpretation.

There's one catch for non-CASPs: the providers you depend on. If your processor or custody partner lost the right to serve EU clients in July, that affects you as well, and a bank may well ask who they are.

For firms registered outside the EU the question is sharper: who are your clients, and how do you keep EU residents out if you aren't authorised here? An answer backed by how your onboarding actually works, such as country checks at sign-up, carries far more weight than a line in your terms of service.

If Your Application Is Still Pending

This is the hardest position to be in, and probably the most common one among smaller firms. A pending application no longer lets you keep serving EU clients. So a banking partner will want to see what you've done about it: which services you've paused, how you're winding down or transferring EU clients, and what activity continues outside the EU.

It isn't a comfortable story to tell. But a documented plan is much easier for a compliance team to work with than "we're nearly there".

How This Works at Polydirection

Crypto is one of the industries Polydirection works with, alongside gambling, forex and dating, and that covers exchanges, wallets and on/off-ramp businesses. Applications are reviewed individually rather than by automated rules, and crypto businesses get a dedicated manager instead of a form-letter decline.

That doesn't make the questions above go away. It does mean there's a person to talk them through with. If your licensing situation is simple, say so and send the register entry. If it's complicated, explain it at the start rather than waiting to be asked. Accounts come with SEPA and SWIFT transfers and multi-currency IBANs, so flows in different currencies can sit in one place.

For the wider picture of opening an EU business account as a crypto company, see our guide for crypto founders. If another provider has already turned you down, our article on individual reviews explains what a second look can and can't change. And if you'd like to talk about your case, contact us.