Türkiye Piyasasında Kripto Hizmetleri İçin MiCAR Geçişi: Yetkili Olmayan VASP’lar İçin Zaman Sınırı ve Tüzükle Uyum Gerekliliği

Italy’s market regulator Consob has begun giving crypto service providers (VASPs) until December 30, 2025, to comply with the EU’s MiCAR regulation; otherwise, they will be required to cease their local operations. This move increases pressure on exchanges and intermediaries targeting local users and compels firms operating as VASPs to work towards recognition as CASPs under MiCAR.

Under the Italian framework, firms currently operating as VASPs can only continue their activities until December 30, 2025, as long as they are registered on the OAM register. However, this transitional period requires pre-authorization under MiCAR, and the process must be monitored until approval is granted in the country where the application is made; but a decision must be made by June 30, 2026, at the latest.

With MiCAR, CASPs must obtain authorization and be subject to ongoing supervision; this shifts the current situation in Italy towards compliance with the broader European regulatory framework in Brussels. Consob has published a detailed notification reflecting the guidance of ESMA and other bodies to make this transition process transparent and orderly; clarifying what retail users should do and outlining the steps operators should take when applying for licenses or planning to exit the market in an organized manner.

Important warning for users towards the end of the year: Investors should check whether firms are providing clear information about their plans, considering that some VASPs may not be able to continue their activities after December 30. They should verify whether the service provider has MiCAR authorization to operate in Italy through the OAM listing or authorized CASP records by ESMA. An unauthorized provider cannot continue offering crypto asset services to the public, and the right to refund customer funds or tokens arises.

On the operator side, Consob has shared guidance steps through previous meetings and public communications. An announcement in September 2024 provided initial instructions to firms, and in July 2025, the national transition period was extended to June 30, 2026. A special warning was also issued on October 31, 2025, for VASPs not listed in the OAM register with MiCAR authorization. Unlicensed VASPs are obliged to cease operations, close existing contracts, and refund crypto assets to customers by December 30, 2025. VASPs listed on OAM must provide clear information on their websites and directly notify customers about the steps they will take (applying for a MiCAR license or orderly market exit).