In short: The MiCA transitional (“grandfathering”) period ends no later than 1 July 2026. After their national deadline, crypto-asset service providers (CASPs) and token issuers must hold full MiCA authorisation to serve EU clients. A linked obligation is already live: since 23 December 2025, the Legal Entity Identifier (LEI) is a mandatory, machine-readable field in crypto-asset white papers. For background on how the LEI fits the wider regulation, see our MiCA regulation spotlight.
What happens on 1 July 2026?
1 July 2026 is the hard deadline for the MiCA transitional regime. Existing providers that operated under national rules before 30 December 2024 were given up to 18 months to secure MiCA authorisation. That window closes on 1 July 2026, and no member state may extend beyond it (ESMA, Statement on the end of transitional periods under MiCA).
Does a MiCA white paper require an LEI?
Yes. Under the technical standards for crypto-asset white papers, the offeror or issuer must include a valid LEI. This is set out in Commission Delegated Regulation (EU) 2025/421, the regulatory technical standards that classify white papers and make their data machine-readable, applicable from 23 December 2025. The forms, formats and templates are governed by Commission Implementing Regulation (EU) 2024/2984.
In practice this means the LEI is no longer a recommendation. It is a required data field in a regulated filing, and that filing has a prescribed machine-readable format.
What format must the white paper take?
Crypto-asset white papers must be prepared in XHTML and use Inline XBRL for the structured data fields, including the issuer’s LEI. This makes white papers machine-readable so regulators and investors can compare disclosures across projects. A white paper that is only a PDF or a webpage does not meet the standard.
Who needs an LEI under MiCA?
Three groups need one:
- Issuers of asset-referenced tokens (ARTs)
- Issuers of e-money tokens (EMTs)
- Crypto-asset service providers (CASPs) operating in the EU
The LEI identifies the entity in its white paper, in regulatory submissions to national competent authorities and ESMA, and in AML and KYC onboarding. Where no other EU-level identifier exists, CASPs must also identify their legal-entity clients by LEI.
What should crypto firms do now?
Treat the LEI as a prerequisite, not an afterthought, because authorisation and white paper filing both depend on it.
- Obtain an LEI for every entity that issues tokens or provides crypto-asset services in the EU.
- Confirm each LEI is active. A lapsed LEI is publicly visible in the Global LEI Index and signals a compliance gap.
- Include the LEI in white papers and regulatory submissions, in the required XHTML and Inline XBRL format.
- Build LEI verification into onboarding so client identification meets MiCA expectations.
If you manage several entities, funds or token structures, track renewals centrally rather than by spreadsheet. One missed renewal can undermine a filing at exactly the wrong moment.
Get MiCA-ready with RapidLEI
RapidLEI is a GLEIF-accredited LEI issuer. We issue LEIs through automated workflows, usually within minutes, with volume management for portfolios of CASPs and token issuers and an API that integrates with exchanges, wallet providers and compliance systems. Already hold an LEI elsewhere? You can transfer it to RapidLEI in minutes with no gap in coverage.
Register an LEI or talk to our compliance team.
FAQ
When does the MiCA transitional period end? No later than 1 July 2026. Several member states closed it earlier, so confirm the deadline in each market where you operate.
Is the LEI mandatory in a MiCA crypto-asset white paper? Yes. The LEI has been a required, machine-readable field in crypto-asset white papers since 23 December 2025, under Commission Delegated Regulation (EU) 2025/421.
What format must a MiCA white paper use? XHTML with Inline XBRL for structured data fields, including the issuer’s LEI.
How quickly can I get an LEI? Through a GLEIF-accredited issuer such as RapidLEI, an LEI is usually issued within minutes.
