MiCA deadline pushes small crypto platforms to outsource compliance functions, centralized risks emerge

MiCA截止日期

On June 19, BitGo Europe GmbH announced a partnership with Warsaw cryptocurrency trading platform Bielik.io, integrating a Crypto-as-a-Service (CaaS) infrastructure to support regulated trading access across the entire European Economic Area. This case shows that under the MiCA deadline, small European platforms can keep their customer-facing brands and applications, while transferring regulated core functions to a licensed provider.

The specific content and service scope of the BitGo–Europe-Bielik.io partnership

Through this integration, qualified Bielik.io users are expected to access deposits, digital asset trading, and custody services via the Bielik mobile application, while BitGo Europe provides the underlying regulated infrastructure.

BitGo Europe’s CaaS product portfolio includes: custody, wallet APIs, user onboarding and KYC, trading and settlement, transfer services, SEPA on/off-ramp channels (if applicable), policy controls, implementation support, and insurance for BitGo’s custodial wallets (subject to the relevant terms).

BitGo Europe’s regulatory status: France’s Autorité des marchés financiers (AMF) lists BitGo Europe GmbH as a MiCA CASP licensed in Germany, authorizing it to provide services free of charge in France, including custody and asset management, crypto-asset exchange funds, exchanges between crypto assets, order execution and transmission, and transfer services.

ESMA’s outsourcing restriction rules: the compliance boundary after July 1

ESMA clearly states that a CASP may not outsource or delegate custody rights to an unauthorized CASP entity, and warns against transferring EU client arrangements through an unauthorized third-country entity. This means that custody outsourcing and routing for cryptocurrencies must remain within the regulatory scope of the service provider.

Small platforms’ options therefore become clear: apply for MiCA CASP authorization themselves; shut down, transfer users, or exit the European market; or look for a licensed infrastructure partner. The CaaS model allows a platform to retain its brand, user experience, and customer relationship, while the provider handles the regulated infrastructure functions.

A pressure-test case in Poland and Lithuania: the situation during the national transition period

Poland: Katowice issued a notice to entities in the virtual currency activities register, stating that starting July 1, 2026, entries in the Polish register will no longer be authorized to conduct virtual currency activities. The Polish president did not sign the draft bill on the crypto-assets market, which was originally planned to take effect on May 15, 2026, leaving some MiCA functions of the domestic competent authorities not yet officially designated. The UKNF also said that MiCA-authorized CASPs from other member states can provide services in Poland under cross-border rules after notifying their home competent authorities, without establishing a local entity.

Lithuania: Its CASP transition period ended on December 31, 2025. Reports show that around 30 companies applied for CASP licenses, and more than 370 companies filed declarations for crypto-asset services; however, based on revenues and financial statement activities, only about 120 were actually operating.

This model has a common thread: the national VASP framework creates a large number of registration or declaration providers, but the threshold for MiCA authorization is higher.

Infrastructure centralization risk brought by MiCA-compliant outsourcing

The article’s core warning is: if more platforms use embedded licensed CaaS providers to secure user access, Europe’s crypto market may concentrate more custody and compliance functions in fewer providers, even while keeping diversity at the application layer.

If integration concentrates among a small number of providers, these providers may gain greater influence over: which assets are supported, how quickly platforms onboard users, how transfers are monitored, which jurisdictions are prioritized for service, and how quickly platforms can recover if a provider changes terms or exits a business line.

The article cites market data: as of June 22, the total cryptocurrency market capitalization is about $2.15 trillion. The Bitcoin price is close to $63,500, and USDT liquidity is about $186 billion—large enough in scale to make strategic functions such as custody, user onboarding, and transfer controls valuable resources to compete for.

FAQ

Is the BitGo-Bielik partnership a common trend before the MiCA deadline?

According to reports, CryptoSlate considers it a “sufficiently specific example that shows a development path that smaller European platforms may take,” rather than a confirmed case of a general trend. The question raised by the article is whether more European platforms will announce similar CaaS integrations before and after July 1.

Do ESMA’s restrictions on outsourcing prevent any form of compliant outsourcing?

Under ESMA rules, the restriction is on outsourcing custody to “unauthorized” entities—not on outsourcing itself. If a provider (such as BitGo Europe) holds a MiCA CASP authorization itself, the path to outsource regulated compliance functions is allowed. The key is that the provider must have authorization for the corresponding services.

What practical impact did Poland’s crypto bill not passing have on the market?

According to reports, because the relevant national bill has not yet entered into force, the UKNF has not yet officially designated the Polish competent authority responsible for certain MiCA functions. However, Poland remains within the MiCA framework, and MiCA-authorized CASPs from other member states can provide services in Poland under cross-border rules after notifying their home competent authorities, without establishing a local entity.

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