Norway

Running in parallel to these new authorisations is a legacy transitional arrangement: providers registered under the prior AML-Act-based VASP regime have been permitted to continue operating without a full CASP licence during a transition window, and this cycle's evidence indicates the Norwegian FSA proposed extending that window from its original 30 December 2025 deadline to 30 June 2026. The stated driver is a heavier-than-expected volume of CASP licence applications reaching Finanstilsynet -- the extension reflects processing-capacity pressure on the regulator rather than a policy softening toward unlicensed activity.

This is best understood as a structurally normal, if temporarily elevated, compliance-fragmentation window rather than a sign of regulatory weakness: MiCA's own transitional provisions anticipate exactly this kind of phased migration from national VASP regimes to the harmonised CASP framework. The practical question for market participants and counterparties is less whether the legal framework is sound, and more which specific entities have completed the transition at any given point in time; a legacy-registered VASP and a MiCA-authorised CASP are not equivalent counterparties from a supervisory-status standpoint, even though both may currently be lawfully operating in the Norwegian market during the extended window.

The evidentiary basis for the specific authorisation dates and the transition-extension mechanics rests on T2/T3 sourcing -- a Schjodt law-firm briefing for the core licensing requirement, and Wintherlaw/GRIP compliance-industry reporting for the extension and the named authorisations. No direct finanstilsynet.no primary-source page was retrieved this cycle confirming either the AK Jensen or Firi authorisation, which is recorded as an evidentiary gap.

Outlook

The 30 June 2026 transition deadline is the clearest near-term marker for this module: whether Finanstilsynet reports a clean migration of the remaining legacy-registered population to full CASP status, announces a further extension, or records a wave of market exits will materially clarify how much of the application backlog the extension was designed to absorb. A primary-source finanstilsynet.no confirmation of the AK Jensen and Firi authorisation dates, and of the precise legal basis for the transition-period extension, would raise confidence on this cycle's findings.

This sequencing is analytically useful: it illustrates one practical pathway by which an established Norwegian platform arrives at MiCA-compliant status for stablecoin-adjacent activity, namely by holding a pre-existing national e-money authorisation that provides regulatory cover for stablecoin-related functions ahead of, and independently of, the separate CASP authorisation process that governs crypto-asset services more broadly. Firi's position -- e-money licence since 2024, CASP licence from May 2026 -- suggests the two authorisation tracks can and do run in parallel for a single entity rather than being sequential prerequisites of each other.

What is not evidenced this cycle is the issuer side of the stablecoin framework: no Norway-domiciled issuer of an asset-referenced token or e-money token under MiCA's issuer-specific authorisation regime was identified. This is a material gap for a complete stablecoin-regime picture, since MiCA distinguishes clearly between the obligations on issuers of ARTs/EMTs and the obligations on CASPs that merely provide services relating to such tokens; this cycle's evidence speaks only to the latter.

Outlook

The item most likely to sharpen this module's picture next cycle is confirmation of whether any Norway-domiciled entity is pursuing, or has obtained, issuer-level MiCA authorisation for an asset-referenced token or e-money token, as distinct from CASP-level service authorisation. Continued tracking of Firi's dual e-money/CASP status, and of whether other Norwegian exchanges follow a similar sequencing pattern, would also help clarify whether this is idiosyncratic to Firi's specific history or a more general pattern among Norwegian crypto-asset platforms transitioning to MiCA compliance.

The practical consumer-protection stakes are direct. Any previously AML-registered exchange or custody provider operating in Norway that did not obtain authorisation by the deadline is now expected to be winding down client relationships in a manner that protects client assets and market integrity rather than exiting abruptly. No Norway-specific enforcement action against a non-compliant wind-down was located within this cycle's evidence, so the practical bite of this expectation — whether Finanstilsynet actively supervises the wind-down process or waits for complaints — is not yet demonstrated in the record available.

The traffic-light assessment reflects that the client-safeguarding expectation itself is explicit and clearly stated for the wind-down cohort, but no Norway-specific enforcement action has yet been found to confirm how that expectation translates into supervisory practice. The governing framework remains the MiCA Regulation (EU) 2023/1114, with Finanstilsynet as the responsible supervisory authority.

Outlook

The key development to watch is whether Finanstilsynet issues any Norway-specific guidance or enforcement action addressing the wind-down cohort directly, which would confirm whether the ESMA expectation is being actively supervised domestically or is being left to the general orderly-wind-down principle without jurisdiction-specific follow-through.

Beyond this specific transfer-service authorisation, broader cross-border transfer controls — such as travel-rule implementation specifics, correspondent arrangements with foreign VASPs, or Norway-specific guidance on outbound/inbound transfer monitoring — were not independently evidenced within this cycle's search. The finding here is narrow: one named entity has a confirmed, in-force authorisation covering this specific service category, rather than a jurisdiction-wide statement of cross-border transfer policy.

The traffic-light assessment reflects that the transfer-service authorisation itself is confirmed for the one entity evidenced, but the broader cross-border control architecture around it — travel-rule mechanics, counterparty due diligence expectations for outbound transfers, and any Norway-specific supervisory guidance — was not independently evidenced this cycle and should not be assumed present or absent on the strength of this single data point.

Outlook

Subsequent cycles should look for whether additional CASPs beyond TÝR Markets AS receive Article 63(j) transfer-service authorisation, and whether Finanstilsynet publishes jurisdiction-specific guidance on travel-rule compliance or cross-border transfer monitoring that would substantiate a broader cross-border transfer regime beyond this single entity's authorisation.