Post-deadline enforcement

MiCA fines calendar: what regulators check first after July 1, 2026

MiCA CASP enforcement is live as of July 1, 2026. There is no single published "fines calendar" — penalties are set nationally, case by case — but the structure of MiCA Title V tells you what a supervisory review is likely to prioritize first.

[VERIFY] There is no official MiCA "fines calendar" document. This page describes likely supervisory priorities based on the structure of Title V, not a confirmed enforcement schedule. Confirm current guidance with your national competent authority (NCA).

What regulators are likely to check first

Title V, Chapter 2's operating-condition articles are not equally weighted in practice. Obligations tied to whether a CASP should have been authorised at all tend to draw scrutiny earliest:

Art. 68
Governance & AML/CFT systems
Foundational to authorisation — absence suggests the CASP shouldn't have been licensed.
Art. 70
Safekeeping of client assets
Client-money segregation failures are the highest-severity, highest-visibility breach type.
Art. 67
Prudential safeguards
Own-funds/insurance minimums are objectively checkable against filed accounts.
Art. 69
Information to competent authorities
A CASP that can't produce requested records is a red flag regardless of the underlying conduct.
[VERIFY] Prioritization above is inference from Title V's structure, not a statement from ESMA or any NCA about audit order. Do not treat this as a confirmed inspection sequence.

Where 'wrote a policy' and 'enforced a policy' diverge

A written AML policy that a compliance officer can produce on request is necessary but is not the same evidence as a log showing that specific transactions were actually evaluated against that policy and blocked or approved accordingly. A regulator asking "show me it working" is asking for the latter.

A pre-execution enforcement layer that records a decision and a hash-chained record for every agent action (see the wallet-level enforcement guide) produces exactly that evidence as a byproduct of normal operation, rather than as a separate reporting exercise.

Start enforcing policy today

MiCA CASP enforcement is active as of July 1, 2026.

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