MiCA Compliance Requirements Statistics 2026: Licences and Fines

A September 17, 2026 snapshot of the European Securities and Markets Authority (ESMA) interim register, published by PaymentProviders.io, listed 352 CASPs authorised under the EU’s Markets in Crypto-Assets Regulation, as published on ESMA’s interim MiCA register. Elliptic’s count at the end of June 2026 found crypto-asset service providers (CASPs) clustered in a few states: Germany led with 55 authorised CASPs, ahead of the Netherlands with 26 and France with 19. Licensing counts are the first of the MiCA compliance requirements statistics that matter, followed by the capital, stablecoin and fine thresholds every firm must meet.

The deadline behind those numbers has passed. Under the Markets in Crypto-Assets Regulation (MiCA), the transitional period expired across the EU on July 1, 2026, and any entity providing crypto-asset services to EU clients without a MiCA licence after that date is in breach of EU law.

Key Takeaways

• The five largest jurisdictions account for 127 of the 213 register entries, close to 60% of the total, according to Elliptic’s June 2026 count.
• The Czech National Bank (CNB) assessed 251 applications and granted authorisation to 11 entities by July 1, 2026, which works out to 11 authorisations against 251 applications and notifications assessed (4.4%).
• 12 EU member states shortened MiCA’s grandfathering period below 18 months, with Latvia, Hungary, the Netherlands, Poland, Slovenia and Finland at 6 months.
• 41 firms were authorised in December 2025 alone, the single largest month in Elliptic’s count to late June 2026, as national filing cut-offs approached.
• Member states must allow fines of at least 3% of annual turnover for white paper breaches and at least 5% for CASP breaches.
• Austria’s Financial Market Authority (FMA) fined Bitpanda GmbH €70,000 for several MiCA breaches in August 2026, according to the FMA’s sanction notice.

Editor’s Choice

• CASPs authorised under MiCA, register snapshot of September 17, 2026: 352.
• Minimum capital for a Class 3 CASP, per MiCA: €150,000.
• Minimum maximum fine for a legal person, per MiCA: €5,000,000.
• Active users that make a CASP significant, per MiCA: at least 15 million in the Union.
• Daily payment-use value in a single currency area that, together with the daily transaction-count threshold, halts issuance of an asset-referenced token, per MiCA: €200,000,000.
• Share of e-money token funds held as bank deposits, per MiCA: at least 30%.

MiCA-Authorised CASPs by Home Member State

• ESMA’s interim MiCA register showed 213 CASP entries holding authorisation across 23 jurisdictions, and the five largest jurisdictions account for 127 of the 213 entries when Elliptic counted them in late June 2026.
• Malta had 15 authorised CASPs and Ireland and Cyprus 12 each.
• Austria had 9, while the Czech Republic, Luxembourg and Spain had 7 each.
• Germany leads by a wide margin, though a large share of its entries are established banks and brokerages taking narrow permissions.
• Most authorised firms have notified an intent to passport widely, according to Elliptic’s late-June 2026 review, which calls the single licence MiCA’s central promise.

Source: Elliptic count of the ESMA interim MiCA register, June 2026

Where is the list of MiCA-licensed crypto firms?

ESMA publishes it. The interim MiCA register consists of five CSV files, including authorised crypto-asset service providers and non-compliant entities, and its last update was on October 7, 2026. The file for issuers of asset-referenced tokens held a header row and no issuer entries when checked on October 14, 2026.

A home-state count shows where firms chose to be supervised, and the pace of approvals shows when they arrived.

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About This Data

Compiled from 17 sources: 14 regulator and official EU publications (ESMA, the European Banking Authority, EUR-Lex, the CNB and the FMA) and 3 independent counts of ESMA’s register. Coverage runs from the regulation text of June 2023 to ESMA’s register update of October 2026. Sources qualify under our statistics methodology: regulation text, supervisor publications and register data only, with figures updated when those sources publish new editions.

MiCA Authorisation Pace and Register Growth

• Authorisations built slowly through 2025 and then spiked.
• 41 firms were authorised in December 2025, as firms raced the national filing cut-offs that cluster around the year end.
• ESMA’s register of authorised CASPs added 41 new entries between July 21 and September 17, 2026.
• 28 of those entries were German Volksbanken and Raiffeisenbanken, each authorised for exactly one MiCA service in one country.
• The 39 Volksbanken and Raiffeisenbanken on the register as of September 17, 2026 make up 41% of Germany’s CASPs in that snapshot, a later and larger German count than the 55 in Elliptic’s late-June tally.
• The register count rose by 139 between Elliptic’s late-June tally and the September 17, 2026 snapshot.

Source: Elliptic, PaymentProviders.io, both counting the ESMA interim MiCA register

The two counts come from different tallies of the same register, and ESMA does not display national authorisations immediately, so the gap may include firms authorised earlier but shown later.

Recent Developments

• October 8, 2026: ESMA said CASPs authorised under MiCA should cease providing services related to non-MiCA-compliant stablecoins to clients in the European Union, with remaining exposures remediated no later than three months after the opinion’s publication.
• October 7, 2026: ESMA’s interim MiCA register received its latest update.
• September 30, 2026: In its response to the European Commission’s public consultation on the MiCA review, ESMA recommended reinforced supervisory powers to deal with third-country firms which solicit EU investors without being authorised under MiCA.
• September 2026: 28 Volksbanken and Raiffeisenbanken were added to ESMA’s MiCA CASP register from July 21 to September 17, 2026, for 39 in total.
• August 14, 2026: The FMA imposed a fine of €70,000 on Bitpanda GmbH, and the penal order is final.
• July 8, 2026: ESMA launched a Common Supervisory Action on the digital operational resilience of CASPs, with a specific emphasis on custody services.

MiCA Licence Applications vs Approvals

• By July 1, 2026, the CNB had assessed a total of 251 applications for authorisation to provide crypto-asset services.
• Of these, 204 applications were submitted during the transitional period.
• The CNB has granted authorisation to 11 entities.
• The CNB received the highest number of applications for authorisation under the MiCA Regulation in the European Union.
• Binance, one of the largest global crypto exchanges, applied for authorisation through the Greek regulator but did not obtain it before the end of the transitional period.

Key finding: The Czech National Bank had assessed a total of 251 applications by July 1, 2026 and granted authorisation to 11 entities. That is 11 authorisations against 251 applications and notifications assessed (4.4%). Because the total mixes new applications with notifications from existing financial firms, the figure measures demand for MiCA permission rather than a pass rate.

MiCA Transitional Period and Grandfathering Deadlines

• CASPs that provided services under applicable law before December 30, 2024 could continue until July 1, 2026 or until granted or refused authorisation, whichever was sooner.
• Member states could decide not to apply the transitional regime or to reduce its duration.
• Germany, Ireland, Lithuania, Austria and Slovakia set 12 months, and Sweden set 9 months.
• Belgium, France, Italy, Malta, Luxembourg and Spain kept 18 months.
• Among EEA countries, Iceland and Liechtenstein set 18 months and Norway 12 months.

Source: ESMA list of grandfathering periods under MiCA Article 143(3)

When did the MiCA transitional period end?

The MiCA transitional period officially expired across the EU on July 1, 2026. ESMA’s April 2026 statement added that by that date any unauthorised CASP must have implemented its wind-down plan. Firms in member states that shortened the window faced the cliff earlier, one reason crypto regulation by country still varied inside the single market.

MiCA Compliance Requirements Statistics: Deadline Timeline

• MiCA applies from December 30, 2024, while Titles III and IV applied from June 30, 2024.
• ESMA’s public statement of June 23, 2026 said unauthorised CASPs must immediately stop onboarding new EU clients.
• Custody of clients’ crypto-assets can only continue for the period strictly necessary to complete an orderly exit.

The milestones show how quickly supervision moved from rule-writing to enforcement, and the capital rules below set the entry ticket for any firm that wants to stay.

MiCA Capital Requirements for CASPs

• Class 1 CASPs, covering order execution, placing, transfer services, reception and transmission of orders, advice and portfolio management, need minimum capital of €50,000.
• Class 2 CASPs, which add custody or exchange of crypto-assets for funds or other crypto-assets, need €125,000.
• Class 3 CASPs, which operate a trading platform for crypto-assets, need €150,000.
• A trading platform needs 3 times the capital of a Class 1 firm.

What are the MiCA capital requirements for CASPs?

MiCA sets minimum capital of €50,000 for Class 1, €125,000 for Class 2 and €150,000 for Class 3 crypto-asset service providers. The class depends on the services a firm is authorised for, with custody and exchange in Class 2 and crypto trading platform operation in Class 3.

Stablecoin Issuer Requirements Under MiCA

• Issuers of asset-referenced tokens (ARTs) must hold own funds of at least the highest of €350,000, 2% of the average reserve of assets, or a quarter of the preceding year’s fixed overheads.
• Issuers of e-money tokens (EMTs) must deposit at least 30% of the funds received in separate accounts in credit institutions.
• The rest must sit in secure, low-risk assets in the same currency the e-money token references.
• ESMA’s register file for issuers of asset-referenced tokens listed no issuers as of October 14, 2026.

Source: Regulation (EU) 2023/1114, Articles 35 and 54

An empty ART file suggests that MiCA-compliant stablecoins in the EU are, for now, e-money tokens, which puts the deposit rule at the center of stablecoin compliance.

MiCA Stablecoin Transaction Caps

• An asset-referenced token used widely as a means of exchange crosses the line above 1 million transactions and €200,000,000 in value per day within a single currency area.
• Its issuer must stop issuing that token and, within 40 working days of reaching the threshold, submit a plan to the competent authority.

Source: Regulation (EU) 2023/1114, Article 23

Why it matters: Article 23 forces an asset-referenced token issuer to stop issuing once payment use passes 1 million transactions and €200,000,000 a day in a single currency area. The rule turns payment success itself into a compliance trigger, so a token that wins wide everyday use has to shrink that use.

MiCA Significance Thresholds

• An asset-referenced token is classified as significant when it meets at least three of the Article 43 criteria, which include more than 10 million holders and a value, market capitalisation or reserve above €5,000,000,000.
• A CASP is deemed significant with at least 15 million active users in the Union, on average, in one calendar year.
• CASPs must notify their competent authorities within two months of reaching that number of active users.

Source: Regulation (EU) 2023/1114, Articles 43 and 85

A token has to meet at least three of those criteria, not just one, before its classification as significant changes the supervision and fine ceiling that apply to its issuer.

MiCA Penalties and Maximum Fines

• For legal persons, member states must set MiCA maximum fines of at least €5,000,000, 3% or 5% of total annual turnover depending on the infringement, with a 12.5% turnover floor for both ART and EMT issuer infringements (shown in the chart below).
• Natural persons face maximum fines of at least €700,000.
• The 3% tier covers infringements of Articles 4 to 14, and the 5% tier covers Articles 59, 60, 64 and 65 to 83, the white paper and CASP rules respectively.
• Under the EBA’s draft fining methodology for the significant-token issuers it supervises, a fine is reduced to 12.5% of annual turnover for an issuer of a significant ART, or 10% for an issuer of a significant EMT, when it is higher than that and the EBA cannot determine the profits gained or losses avoided.
• The EBA consulted on its fine-setting methodology until September 28, 2026.

What are the penalties for MiCA non-compliance?

National authorities must be able to fine legal persons at least €5,000,000 or 3% or 5% of annual turnover depending on the infringement, with a higher turnover floor for ART and EMT issuers, and natural persons at least €700,000. Those are floors for the maximum fine a supervisor can impose, not minimum fines, and the published Austrian case came in far lower: the FMA fined Bitpanda GmbH €70,000.

Worth noting: The FMA said Bitpanda GmbH failed to submit a crypto-asset white paper at latest 20 working days before publication and issued a marketing communication before the white paper. On October 1, 2026, the FMA began a procedure to review the legality of the publication at the request of Bitpanda GmbH.

White Paper Rules for Token Offers

• Offers to fewer than 150 natural or legal persons per member state, acting on their own account, are exempt from core white paper duties.
• So are offers whose total consideration does not exceed €1,000,000 over 12 months.
• Offers addressed solely to qualified investors, where only those investors can hold the crypto-asset, are also exempt.
• Bitpanda’s case turned on a white paper submitted less than 20 working days before publication.

Source: Regulation (EU) 2023/1114, Article 4(2)

White paper timing is one of the MiCA rulebook’s duties a firm controls directly, and the Austrian case shows a supervisor already enforcing it.

MiCA Supervision: Peer Reviews and Enforcement

• ESMA’s peer review of the Malta Financial Services Authority (MFSA) found that some material issues were not fully resolved when MFSA granted the CASP authorisation.
• The review asked all national authorities to watch business growth, conflicts of interest, governance, ICT architecture, Web3 and decentralised products.
• ESMA’s custody resilience exercise runs from the second half of 2026 to the first half of 2027.
• ESMA also wants explicit rules that stop regulated crypto firms from offering services linked to stablecoins that do not comply with MiCA.

Source: ESMA, EBA

Conclusion

ESMA’s register listed 352 CASPs authorised under MiCA in its September 17, 2026 snapshot, and the transitional period ended across the EU on July 1, 2026. The data shows a licensing market split between domestic registrations, many of them German banks and brokerages taking narrow permissions, and crypto-native hubs such as Malta, the Netherlands and Cyprus, while the CNB granted 11 authorisations against 251 applications and notifications.

The next tests are the stablecoin remediation window from ESMA’s October opinion and the Commission’s MiCA review, where ESMA’s consultation response asked for reinforced supervisory powers to deal with third-country firms. Firms that cleared authorisation now face supervision of how they run custody, marketing and stablecoin services.