# MiCA CASP authorisation-withdrawal forensic register Crypto-Asset Service Providers and pre-MiCA DASPs under MiCA transitional measures must know whether authorisations were revoked, voluntarily cancelled, refused, lapsed or not re-authorised. This forensic register maps 29 named withdrawals across AMF, MFSA and CySEC at the 2026-05-03 cut-off, classified into five withdrawal types. XZiel recused. - Source: https://finray.tech/intelligence/mica-casp-authorisation-withdrawals/ - Cluster: XZiel - Published: 2026-05-03 - Updated: 2026-05-03 - Conflict of interest: Finray Technologies Ltd ships XZiel. XZiel is recused from any qualitative ranking on this page. - Publisher: Finray Technologies Ltd, Cyprus Companies Registry HE 445903 - Editorial principle: primary sources only; conflicts of interest disclosed inline --- The MiCA-CASP licensing-success register names every entity that got through the gate. This register names every entity that did not — or that walked away from the gate — and classifies the exit into one of five withdrawal types. It is the counter-narrative to the success population, and it ships at 29 verified entities across three primary-source NCAs. Companion artefact: MiCA CASP licensing-success forensic register, the 177-record success population this register inverts. ## Methodology The five withdrawal-type classes used here mirror the EMI / PI failure register taxonomy: - `regulator-revocation` — the regulator revoked the authorisation under enforcement powers, with a named decision document. France's AMF publishes a délibération decision for every PSAN / DASP enforcement-driven revocation; CySEC publishes per-decision board minutes for CASP register deletions. - `voluntary-cancellation` — the firm requested delisting; no enforcement action visible in the public record. France's AMF and Malta's MFSA both publish per-entity decisions for this class (AMF délibération PDF or MFSA "surrender of licence" notice). - `application-refused` — the applicant never reached authorised state. Refusal data is largely not published; MFSA is the only NCA in the current cohort that publishes "Decision not to grant licence" notices. - `lapsed-without-renewal` — authorisation expired and the firm did not renew. CASP / pre-MiCA national authorisations do not have fixed expiries under EU law, so this class is rarely populated outside specific national registers; CySEC's Deregistered CASPs page is the only current source where rows exist without a separate decision document or effective date. - `regime-transition-non-completed` — the firm failed to re-authorise under MiCA from a pre-MiCA national VASP / DASP / Kryptoverwahrgeschäft regime. This is the class that will populate the most as the MiCA transitional period ends 1 July 2026 across most Member States, and 30 December 2025 already passed for Italian OAM ex-officio cancellations. Reasons (AML failure, custody segregation, governance) are not encoded — they are legal commentary that lives in the linked source document, not in this structured index. ## Population landscape 29 named entities across three NCAs: - **AMF (France) — 20 entities.** 15 voluntary-cancellation, 3 regulator-revocation, 0 application-refused, 0 lapsed-without-renewal, 2 regime-transition-non-completed. The historical anchor: AMF publishes a per-entity délibération PDF for every PSAN / DASP delisting since 2020 — the cleanest historical trail in the EEA. Coverage spans 2022 (BYKEP SAS) through April 2026 (Coinbase Europe, Coinbase Custody International, Coinmerce, plus the recent voluntary cluster: VAULT4CRYPTO, GOAT, PALISADE FINANCIAL, RIALTO). - **MFSA (Malta) — 5 entities.** 3 voluntary-cancellation (Mint Exchange, Bequant Exchange, AMoney Ventures — surrender-of-licence notices) and 2 application-refused (MoonPay, NMVA — "Decision not to grant licence" notices, both for Class 2 / Class 4 Virtual Financial Assets licence applications). MFSA is currently the only NCA in the cohort with public application-refused decisions. - **CySEC (Cyprus) — 4 entities.** 2 regulator-revocation (Binance Cyprus, IQOPTION EUROPE — both deleted from the CASP Register by board decision in August 2023) and 2 lapsed-without-renewal (GTCAP IO, Panteresa Investments — Deregistered-CASPs register rows where no separate decision or effective date is published, conservatively classified). CySEC also operates a 27 February 2026 MiCA application deadline; further deregistration cohorts are expected. Other NCAs do withdraw or de-register pre-MiCA crypto authorisations — the Italian OAM has signalled that operators who did not apply for CASP authorisation by 30 December 2025 will be cancelled ex officio; BaFin (Germany) maintains a Kryptoverwahrgeschäft register and a separate "Maßnahmen" enforcement page — but neither publishes the per-entity withdrawal decision in a deep-linkable URL format that this register's discipline rules currently accept. The register will absorb new primary-source decisions on a signal-driven cadence as they become published. ## Withdrawal-type distribution In the 29-entity population: - `voluntary-cancellation`: 17 records (AMF 14 + MFSA 3). Includes the AMF 2024–2025 restructuring cluster (LiteBit, BUX, AXA, Luno France, OKX France, HedgeGuard, Vivid Digital, Voyager Europe, Bitpanda, EMMANUEL MANAGEMENT, plus the April 2026 cluster: VAULT4CRYPTO, GOAT, PALISADE FINANCIAL, RIALTO) and the MFSA surrender cluster (Mint Exchange, Bequant Exchange, AMoney Ventures). - `regulator-revocation`: 5 records (AMF 3 + CySEC 2). BYKEP SAS in 2022 and the December 2024 AMF pair (Digital Exchange / Zebitex, Digital Broker / Zebitcoin), plus the August 2023 CySEC pair (Binance Cyprus, IQOPTION EUROPE). - `application-refused`: 2 records (MFSA only). MoonPay Limited (2021-07-09) and NMVA Limited (2022-02-22), both VFA-regime "Decision not to grant licence" decisions. - `lapsed-without-renewal`: 2 records (CySEC only). GTCAP IO Ltd and Panteresa Investments Ltd, both Deregistered-CASPs register rows without separate effective dates — conservatively classified, see source URL on each row. - `regime-transition-non-completed`: 3 records (AMF only). Coinbase Europe, Coinbase Custody International, Coinmerce — April 2026 exits from the French DASP list driven by failure to transition to a France-licensed CASP. The pattern across all three NCAs is consistent: most pre-MiCA delistings in 2024–2025 are voluntary and operationally driven (consolidation, restructuring, exit from a sub-scale market) rather than enforcement-driven. Application-refused and lapsed-without-renewal classes are populated only where the source NCA publishes the relevant decision format (MFSA for refusals; CySEC's deregistered-CASPs register for lapses). Once the MiCA transitional period ends, the regime-transition class is expected to become the dominant withdrawal type across the EEA. ## Forward-look The MiCA transitional period ends 1 July 2026 in most Member States. The Italian OAM has signalled that operators who did not file a CASP authorisation application by 30 December 2025 will be cancelled ex officio. The German MiCAR transitional regime allows pre-MiCA Kryptoverwahrgeschäft licence holders to continue under existing supervision until 31 December 2025, with extension provisions thereafter. CySEC has set 27 February 2026 as the MiCA application deadline for existing CASP-authorised firms under the Cyprus national regime. Each of these milestones is a forward indicator that the `regime-transition-non-completed` class will populate in the second half of 2026 and through 2027. When additional NCAs begin publishing per-entity ex-officio cancellation lists or refusal decisions in machine-findable form (BaFin Maßnahmen, ACPR public decisions, OAM cancellation notices), this register will absorb them. The current 29-entity population is constrained by what regulators publish today, not by underlying withdrawal volume. ## Data-quality limitations Three limitations apply. First, the four CySEC and the two MFSA application-refused rows are sourced from regulator portal pages rather than délibération-style PDFs; readers should follow the source URL on each row for the full reasoning. Second, two CySEC rows (GTCAP IO, Panteresa Investments) carry no public effective date because the CySEC Deregistered-CASPs register exposes the entity row but no standalone deletion decision; both are conservatively classified as `lapsed-without-renewal`. Third, there is no public denominator of refused MiCA-CASP applications EU-wide, so authorisation success rates cannot be computed from this artefact alone — MFSA's two refusals are unique current data points. This is a structured-index page, not a legal commentary. For corrections to entity classifications or new primary-source URLs to add cross-NCA coverage, write to legal@finray.tech. --- ## Reference index ### Institution classes / Pre-MiCA archetypes (5) - **Regulator-driven revocation** — 5 of 29 records — Authorisation revoked by the regulator under enforcement powers (named regulator decision). - **Voluntary cancellation** — 17 of 29 records — Firm requested cancellation of authorisation; no enforcement action. - **Application refused** — 2 of 29 records — Applicant never reached authorised state and the regulator refused authorisation. - **Lapsed without renewal** — 2 of 29 records — Authorisation expired and was not renewed; firm did not transition to a new regime. - **Regime-transition not completed** — 3 of 29 records — Firm failed to re-authorise under MiCA from a pre-MiCA national VASP / DASP / Kryptoverwahrgeschäft regime. ### Jurisdictions (3) - **France (FR)** (FR, 20 entities) — France — AMF (Autorité des Marchés Financiers) publishes per-entity délibération PDFs for every PSAN / DASP delisting. The cleanest historical trail in the EU. - **Malta (MT)** (MT, 5 entities) — Malta — MFSA (Malta Financial Services Authority) publishes per-entity surrender-of-licence and application-refused notices for VFA Service Provider firms; primary-source pages at mfsa.mt/publication. - **Cyprus (CY)** (CY, 4 entities) — Cyprus — CySEC (Cyprus Securities and Exchange Commission) maintains both per-decision deletion records under public-info/decisions and a Deregistered CASPs register page; primary-source pages at cysec.gov.cy. ### Licensed entities (29 total) Status / scope / source-register URL columns are inferences from observable register fields where not directly exposed by the source register; see the editorial methodology page for the inference rules. #### France (FR) (20) - **2525 Ventures B.V. (LiteBit)** — Voluntary cancellation; scope: voluntary-cancellation - **AXA Investment Managers IF SA** — Voluntary cancellation; scope: voluntary-cancellation - **BITPANDA SAS** — Voluntary cancellation; scope: voluntary-cancellation - **BUX Alternative Investments B.V.** — Voluntary cancellation; scope: voluntary-cancellation - **BYKEP SAS** — Regulator-driven revocation; scope: regulator-revocation - **Coinbase Custody International Limited** — Regime-transition not completed; scope: regime-transition-non-completed - **Coinbase Europe Limited** — Regime-transition not completed; scope: regime-transition-non-completed - **Coinmerce SAS** — Regime-transition not completed; scope: regime-transition-non-completed - **DIGITAL BROKER SAS (Zebitcoin)** — Regulator-driven revocation; scope: regulator-revocation - **DIGITAL EXCHANGE SAS (Zebitex)** — Regulator-driven revocation; scope: regulator-revocation - **EMMANUEL MANAGEMENT SAS** — Voluntary cancellation; scope: voluntary-cancellation - **GOAT SAS** — Voluntary cancellation; scope: voluntary-cancellation - **HedgeGuard Financial Software SAS** — Voluntary cancellation; scope: voluntary-cancellation - **Luno France SAS** — Voluntary cancellation; scope: voluntary-cancellation - **OKX France Technology Company Limited SAS** — Voluntary cancellation; scope: voluntary-cancellation - **PALISADE FINANCIAL SAS** — Voluntary cancellation; scope: voluntary-cancellation - **RIALTO SAS (anciennement ATLENDIS FLOW SAS)** — Voluntary cancellation; scope: voluntary-cancellation - **VAULT4CRYPTO (EX-ELYPS) SAS** — Voluntary cancellation; scope: voluntary-cancellation - **Vivid Digital S.r.l.** — Voluntary cancellation; scope: voluntary-cancellation - **Voyager Europe SAS** — Voluntary cancellation; scope: voluntary-cancellation #### Malta (MT) (5) - **AMoney Ventures Limited** — Voluntary cancellation; scope: voluntary-cancellation - **Bequant Exchange Ltd** — Voluntary cancellation; scope: voluntary-cancellation - **Mint Exchange Ltd** — Voluntary cancellation; scope: voluntary-cancellation - **MoonPay Limited** — Application refused; scope: application-refused - **NMVA Limited** — Application refused; scope: application-refused #### Cyprus (CY) (4) - **Binance Cyprus Ltd** — Regulator-driven revocation; scope: regulator-revocation - **GTCAP IO Ltd** — Lapsed without renewal; scope: lapsed-without-renewal - **IQOPTION EUROPE LTD** — Regulator-driven revocation; scope: regulator-revocation - **Panteresa Investments Ltd** — Lapsed without renewal; scope: lapsed-without-renewal