As 2025 draws to a close, the European Union is entering a decisive phase in its effort to harmonize digital asset regulation under the Markets in Crypto-Assets (MiCA) framework.
This year has marked the most significant structural shift in the compliance obligations of crypto‑asset service providers since the early VASP (Virtual Asset Service Provider) regimes were adopted at the member‑state level.
Now, as national regulators race to implement and operationalize CASP (Crypto‑Asset Service Provider) licensing procedures, the reality on the ground has become clear: the transition is not smooth — and the clock is ticking.
The Regulatory Bottleneck Everyone Saw Coming
Across the EU, national competent authorities are facing severe application backlogs, resulting from the compressed timeline to align with MiCA’s enforcement schedule.
Many jurisdictions — including those that historically moved quickly under AMLD5‑based VASP frameworks — are now struggling to process hundreds of CASP license submissions simultaneously.
Three key challenges are emerging:
- Limited regulatory capacity: Many smaller jurisdictions underestimated the volume of CASP applications.
- Unclear transitional rules: Some VASP licensees still operate in legal grey zones, awaiting formal conversion guidance.
- Operational readiness: Firms are discovering that CASP compliance requires deeper governance, disclosure, and transparency mechanisms than VASP regimes demanded.
For regulated entities and startups alike, this means one thing: delays are inevitable unless preparation starts now.
How Hacken Advisory Interprets the Landscape
At Hacken, we see a multi‑speed Europe forming — not in the legal text of MiCA, but in its real‑world rollout. Countries with established VASP infrastructure, such as Estonia and Lithuania, are ahead in aligning procedures, while others are still issuing temporary guidance.
Our ongoing research into regional CASP adoption trends shows:
- Average licensing times are 30–50% longer than initial regulator estimates.
- Demand for advisory consultations has doubled since Q3 2025.
- Cross‑border consistency remains one of the biggest pain points for multinational crypto operators.
This transitional friction is not only administrative. It’s reshaping the competitive dynamics of Europe’s crypto economy.
The Opportunity Within the Slowdown
Periods of regulatory change bring uncertainty — but also clarity.
MiCA’s uniform CASP framework, once fully operational, will finally give legitimate players the level playing field they’ve sought for years.
Firms that act early, anticipate auditor expectations, and document compliance rigorously will emerge as trusted leaders in the new regulated era of digital assets.
At Hacken, we’ve spent the past quarter deeply engaged with policy experts, legal practitioners, and compliance teams across the EU — providing real‑time insights on national adaptations and helping clients bridge the gap between VASP legacy systems and CASP future requirements.
What Comes Next
With only weeks left before key MiCA milestones, we expect to see:
- Accelerated last‑minute submissions from firms that delayed their CASP filings.
- Secondary guidance waves from regulators clarifying operational requirements.
- A consolidation trend among smaller crypto service providers who cannot meet the CASP compliance threshold independently.
Hacken Advisory will continue monitoring these developments, offering both technical assessments and policy intelligence to help the Web3 ecosystem navigate the shifting terrain of European regulation.
Our Takeaway
The road from VASP to CASP is not a straight line — but it’s a necessary one.
Compliance, once seen as a reactive cost, is rapidly becoming a strategic differentiator in the EU digital asset space.
At Hacken, we’re committed to ensuring the transition doesn’t just meet regulatory expectations — it sets new standards for transparency and accountability across the industry.
If your organization is preparing for CASP licensing or needs clarity on specific jurisdictional timelines, our compliance and research teams are here to assist.
