Cyprus VASP Register 2026 — Transitional Regime, CASP Migration, July 2026 Deadline

1. The original Cyprus VASP register (2021-2024)

Cyprus's pre-MiCA VASP register was established by Cyprus AMLA (Anti-Money Laundering Authority) under Law 188(I)/2007 + Cyprus crypto-asset directives from 2021. CySEC supervised the register. Registration was lighter-touch than full MiFID II or AIFM authorisation — focused on AML / counter-terrorism-financing compliance.

2. What's covered by transitional regime

• Pre-existing CySEC VASP registrants (registered before 30 December 2024).
• Crypto-asset services explicitly authorised on the VASP register: custody, exchange of crypto for fiat / crypto for crypto, execution of orders, portfolio management on crypto, advice on crypto, transfer services.
• Continued operation under existing VASP scope through transitional period.
• AML / CFT obligations under Law 188(I)/2007 continue.

3. The 1 July 2026 deadline

Mandatory transition by 1 July 2026:

1. 1Pre-existing VASP registrants must submit a CASP application by ~end-Q1 2026 to leave realistic margin for CySEC review.
2. 2By 1 July 2026, either a CASP authorisation must be granted OR a decision issued (positive or negative).
3. 3Pending applications: continue under transitional regime past 1 July 2026 until decision issued.
4. 4After 1 July 2026, unauthorised crypto-asset services illegal — criminal sanctions for non-compliance.
5. 5Operators who don't apply by mid-2026: must cease operations + may transition to a passporting model from another EU CASP.

4. CASP migration playbook

• Step 1 — review current VASP scope vs intended CASP scope (some VASP scope may not map directly).
• Step 2 — pre-application engagement with CySEC (1-2 months) — confirm tier, file requirements, capital adequacy.
• Step 3 — prepare CASP application file: governance, AML, ICT / DORA, capital, business plan.
• Step 4 — submit CASP application to CySEC.
• Step 5 — respond to clarification requests (typical 1-3 rounds).
• Step 6 — receive CASP decision (typically 6-9 months from submission for clean files).
• Step 7 — operational transition under full MiCA CASP regime.

5. Capital + governance — VASP vs CASP

• VASP capital: light-touch under AML framework — no fixed prudential minimum.
• CASP capital: MiCA Annex IV — €50k (Tier 1: advice, transfer, RTO) / €125k (Tier 2: custody, exchange, execution, placing, portfolio management) / €150k (Tier 3: trading platform).
• VASP governance: AML / MLRO required.
• CASP governance: full senior management + compliance + risk officer + ICT + DORA + AML + DAC8 reporting.
• Material uplift in governance + capital + reporting burden post-CASP.

6. Cost comparison + economic decision

Pre-existing VASPs face a material decision:

• Apply for CASP — fully regulated, EU passport via MiCA Article 65, can expand services within MiCA scope.
• Cease Cyprus operations — discontinue crypto-asset services in Cyprus from 1 July 2026.
• Passport into Cyprus from another EU member state — if another EU CASP authorisation is held, passport instead of separate Cyprus CASP.
• Wind-down + relocate non-Cyprus — exit Cyprus VASP register + operate from another jurisdiction.

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Disclaimer: This article is for informational purposes only and does not constitute legal, tax, or financial advice. Tax laws change frequently. Consult a qualified Cyprus adviser for guidance specific to your situation. The information on this page is general guidance only and does not constitute legal, tax, accounting, immigration or financial advice. Specific advice should be obtained based on the facts of each case.