MiCA Regulations Impact on Crypto Businesses Statistics 2026: Navigating the New Era of Crypto Compliance

The European Union’s Markets in Crypto-Assets Regulation has cut the bloc’s crypto-asset service provider count from over 3,000 legacy registrations to 102 fully authorised firms at MiCA’s one-year mark, with 30 active stablecoin issuers and 12 credit institutions holding licences as of December 2025. The figures expose a regime that did what its drafters promised: replace a patchwork of national virtual-asset rules with a single rulebook policed by a coordinated network of regulators.

The numbers also mark a clean break with the pre-MiCA market. What was once a permissive, fragmented landscape has become a gatekept harmonised one, and the firms that survived the transition look very different from the firms that registered before it.

Key Takeaways

• The ESMA register listed 102 crypto-asset service providers operating in the EU with full MiCA authorisation as of December 2025, a tally that excludes firms still operating under transitional arrangements.
• Pre-MiCA, over 3,000 CASP registrations had been issued across the EU, though TRM Labs estimated the true number of operational firms at 1,100 to 1,300.
• Stablecoin issuance under MiCA remains concentrated, with just 30 active stablecoin issuers across the bloc.
• Banks have taken a meaningful share of the new licences: 12 of the 102 authorised CASPs are credit institutions.
• The transitional regime tops out at 18 months, ending on 30 June 2026, though individual Member States may shorten it.
• By 2 March 2026, CASPs transferring electronic money tokens must hold a PSD2 authorisation in addition to their MiCA licence.
• The EU’s MiCA-designated competent authority network spans all 27 EU Member States plus the three EEA states of Iceland, Liechtenstein, and Norway.

Editor’s Choice

• MiCA entered into force on 29 June 2024, with full CASP authorisation requirements applying from January 2025.
• ESMA’s April 2025 snapshot recorded 17 CASPs authorised across 7 EU Member States in the first quarter of MiCA’s CASP regime.
• The Q1 2025 non-compliant register listed 15 entities, all reported by CONSOB in Italy.
• ESMA expects national regulators to treat “last minute” applications for MiCA authorisation with “considerable caution” in 2026.
• The European Commission has proposed centralising CASP supervision within ESMA, shifting oversight away from national authorities, as reported in BBVA’s one-year MiCA review on 24 December 2025.

Recent Developments

• December 2025: ESMA published its statement on the end of MiCA transitional measures (ESMA75-113276571-1631), reminding NCAs to enforce against unauthorised CASPs as the remaining grandfathering windows closed.
• December 2025: The European Commission proposed centralising CASP supervision within ESMA, moving day-to-day oversight away from national NCAs.
• October 2025: The Joint ESAs published a consumer factsheet defining the three crypto-asset categories MiCA covers: EMTs, ARTs, and other crypto-assets.
• July 2025: ESMA released its fast-track peer review (ESMA42-2004696504-8164) on the Malta Financial Services Authority’s CASP authorisation and supervision, with recommendations binding on every EU NCA.
• June 2025: The EBA published its No Action letter on the PSD2/MiCA interplay for CASPs transacting electronic money tokens, deferring PSD2 enforcement until 2 March 2026.
• February 2026: ESMA’s list of Article 93 competent authorities was last updated on 17 February 2026, covering 30 jurisdictions across the EU and EEA.

CASP Authorisation Pipeline Under MiCA

• The ESMA register listed 102 CASPs operating in the EU with full MiCA authorisation as of December 2025.
• ESMA’s earlier April 2025 snapshot showed only 17 CASPs authorised across seven EU Member States, illustrating how quickly the pipeline accelerated through 2025.
• 32 crypto-asset firms were formally recognised at the pan-European level in Q1 2025, split between the authorised and non-compliant lists.
• The ESMA register excludes entities operating temporarily under the transitional regime, so the headline 102 figure understates the active operator base.
• Any new market entrants post-31 December 2024 must obtain full MiCA authorisation before beginning operations.

Source: ESMA Interim MiCA Register; TRM Labs Q1 2025 analysis

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How many crypto firms have been authorised under MiCA so far?

ESMA’s register counted 102 fully MiCA-authorised CASPs as of December 2025, including 12 credit institutions. The total excludes firms still operating under transitional grandfathering, with the deadline for those to convert set at 30 June 2026. The pace accelerated sharply from the Q1 2025 snapshot of only 17 authorisations across seven Member States.

By the numbers: Across the first year of MiCA, the ESMA register grew from 17 authorised CASPs in seven Member States (April 2025) to 102 fully authorised firms (December 2025), per ESMA’s own data cited in BBVA’s one-year review. The trajectory still leaves hundreds of pre-MiCA operators racing the 30 June 2026 grandfathering deadline.

Pre-MiCA Versus Post-MiCA Market Concentration

• Pre-MiCA, over 3,000 CASP registrations or licences had been issued across the EU, though scope and substance varied significantly by jurisdiction.
• TRM Labs estimated the true number of operational pre-MiCA CASPs at 1,100 to 1,300 based on its proprietary methodology.
• That estimate contrasts with the 102 fully authorised CASPs ESMA listed in December 2025, pointing to a sharp consolidation.
• TRM Labs anticipated a net contraction in CASPs operating under MiCA, even as the regime enhances regulatory certainty.
• Pre-MiCA registrations “varied significantly in scope and substance” across jurisdictions, per TRM Labs’ Q1 2025 analysis, so the pre-MiCA headcount overstated the operational footprint.

Crypto firms can verify the regulatory footprint of an exchange via CoinLaw’s crypto exchange market share data alongside the ESMA register before opening accounts.

Stablecoin Issuer Approvals Under MiCA

• The MiCA-authorised stablecoin issuer pool sits at 30 active issuers across the EU as of December 2025, a thin layer next to the 102 authorised CASPs.
• 2 stablecoin categories carry distinct authorisation pathways: asset-referenced tokens (ARTs) and electronic money tokens (EMTs).

Only credit institutions or e-money institutions may offer EMTs publicly in the EU, while ARTs may be issued only by credit institutions or MiCA-authorised issuers. Per the Joint ESAs factsheet, neither ARTs nor EMTs may grant interest to holders, a structural limit that has reshaped product design for European stablecoins. The table below sets out how each token type is permitted, redeemed, and restricted.

Source: Joint ESAs Factsheet on Crypto-Assets (October 2025); MiCA Regulation Titles III and IV

National Competent Authority Landscape Across the EU

• MiCA’s competent authority network spans all 27 EU Member States plus the three EEA states: Iceland, Liechtenstein, and Norway.
• Several Member States, including France, Germany, Italy, and Cyprus, designate two competent authorities under Article 93, splitting prudential and conduct supervision.
• Major NCAs include BaFin (Germany), AMF and ACPR (France), AFM (Netherlands), MFSA (Malta), CySEC (Cyprus), CSSF (Luxembourg), CNMV (Spain), CONSOB (Italy), Finanssivalvonta (Finland), and the Central Bank of Ireland.
• Italy’s CONSOB was the sole NCA reporting non-compliant entities to ESMA in Q1 2025, contributing all 15 listings.
• ESMA’s role under Article 93 is limited to publishing the authority list. Member States retain the designation power.

Which EU country has issued the most CASP licences?

Germany leads the publicly reported CASP authorisations under MiCA, with BaFin granting the highest single-NCA count by end-2025, though ESMA does not publish per-country tallies on its core register. The 102 figure is bloc-wide. Country-level concentration reflects how aggressively each NCA shortened its national transitional regime relative to MiCA’s full 18-month grandfathering window.

MiCA Transitional Regime and Member State Divergence

• MiCA’s transitional regime permits firms operating under prior national law to continue until 30 June 2026, an 18-month grandfathering window.
• Article 143(3) gives individual Member States complete discretion not to apply the transitional regime or to reduce its duration, producing divergent national timelines.
• ESMA noted that this approach has resulted in “different transitional periods applicable across EU Member States, creating uneven enforcement timelines.
• ESMA expects CASPs not yet authorised to have implemented “orderly wind-down plans” for Member States where the transitional period has ended.
• The same statement called on NCAs to “be ready to enforce against the unauthorised provision of crypto-asset services”.

Source: ESMA statements ESMA75-113276571-1631 (December 2025) and ESMA75-223375936-6099 (January 2025); EBA No Action letter (June 2025)

When does the MiCA transitional period end?

The MiCA transitional regime tops out at 30 June 2026, an 18-month grandfathering window from the 30 December 2024 application date of Title V. National regulators may shorten that window for their own jurisdictions under Article 143(3), so the actual deadline a CASP faces depends on where it is based. Germany, the Netherlands, and several others applied shorter periods.

MiCA Authorisation Standards After the MFSA Peer Review

• ESMA’s July 2025 peer review of the Malta Financial Services Authority (ESMA42-2004696504-8164) set baseline CASP authorisation expectations for every NCA.
• The Peer Review Committee graded MFSA across 3 areas: supervisory settings and resources (“fully meeting expectations”), supervisory review and powers (“largely meeting”), and the authorisation process (“partially meeting”).
• ESMA directed all NCAs to 5 forward-looking attention areas: business growth, conflicts of interest, governance and intragroup arrangements, ICT architecture under DORA, and Web3 / decentralised products.

The committee questioned the timing of the specific Maltese authorisation, finding that several material issues remained unresolved when MFSA cleared the entity. That gap is what dropped the authorisation process to the lowest of the three grades and prompted the EU-wide recommendations below.

Key finding: Per ESMA’s Peer Review Committee, the Malta authorisation case showed that “several material issues remained unresolved at the time of the authorisation,” prompting EU-wide recommendations to pay particular attention to business growth, conflicts of interest, governance and intragroup arrangements, ICT architecture including DORA requirements, and Web3 and decentralised products.

Operational Compliance Burdens on Authorised CASPs

Operationally, the five peer-review attention areas translate into live authorisation tests: ESMA expects NCAs to probe an applicant’s business-growth plans, conflicts of interest, governance and intragroup arrangements, ICT architecture under DORA, and any Web3 or decentralised products before clearing a licence. The burden does not end there.

Beyond MiCA’s own demands, EMT-transacting CASPs face overlapping PSD2 obligations including strong customer authentication (SCA) for custodial wallets, payment fraud reporting, and own funds calculations.

Stablecoin Service Restrictions on Non-Compliant ARTs and EMTs

• ESMA’s January 2025 statement instructed NCAs that “CASPs operating a trading platform for crypto-assets are expected to stop making all crypto-assets that would qualify as ARTs and EMTs but for which the issuer is not authorised in the EU available for trading”.
• Other CASP services affected include reception and transmission of orders, execution of orders on behalf of clients, and exchange of crypto-assets for funds or other crypto-assets.
• “The restrictions on the existing services are expected to be completed by the end of January 2025” for any offering that constitutes an offer to the public.
• ESMA permitted a “sell only” basis for these products until the end of Q1 2025 so EU investors could liquidate or convert their positions.
• NCAs were told to “ensure compliance by CASPs regarding non-compliant ARTs or EMTs as soon as possible and no later than the end of Q1 2025”, with ESMA coordinating timing.

Are stablecoins like USDT and USDC banned in the EU under MiCA?

USDC is offered by issuers authorised under MiCA’s EMT framework, so it remains tradable on MiCA-authorised CASPs. ESMA’s January 2025 statement instructed CASPs operating a trading platform to “stop making all crypto-assets that would qualify as ARTs and EMTs but for which the issuer is not authorised in the EU available for trading”. EU CASPs could, however, maintain crypto-asset services for these products on a “sell only” basis until the end of Q1 2025, allowing EU investors to liquidate or convert their positions.

PSD2 and MiCA Overlap for EMT-Transacting CASPs

• The EBA’s June 2025 No Action letter tells NCAs to enforce PSD2 authorisation for EMT-transacting CASPs only after a transition period ending 2 March 2026.

During the transition, NCAs should apply streamlined procedures that reuse the information firms already supplied at CASP authorisation. Under PSD2, transferring crypto-assets counts as a payment service where the assets are EMTs moved on behalf of clients, so the EBA letter extends strong customer authentication to custodial wallets that qualify as payment accounts and to the initiation of EMT transfers. Even past the deadline, NCAs are advised to keep insisting on SCA for wallet access, payment-fraud reporting, and cumulative own-funds calculations.

For background on the broader payments standards, see CoinLaw’s crypto exchanges coverage of the authorisations that are most directly affected.

Bank and Credit Institution Participation in CASPs

• Banks account for 12 of the 102 authorised CASPs on the ESMA register as of December 2025.

Credit institutions can offer EMTs to the public, or seek their admission to trading, without a separate e-money-institution licence, and they may do the same for ARTs, placing banks in both stablecoin categories. BBVA credits the bank track with helping expand the range of secure services available to retail customers. Institutional investors and bank-issued crypto products now sit under the same MiCA umbrella as native crypto firms, which equalises the regulatory burden across both operator categories.

Cross-Border Passporting and the Hub Business Model

• The Board of Supervisors agreed a coordinated CASP-authorisation approach in December 2024, a structural step toward harmonising how NCAs approve cross-border CASPs.
• That coordinated approach predated the April 2025 launch of the MFSA peer review, a sign NCAs already read the hub model as a co-ordination risk.

The peer review framed the Maltese hub as a competence question rather than a capacity one, noting MFSA had built good sector expertise and sufficient supervisory resources. Even so, the committee questioned the timing of the specific authorisation while material issues were open, a signal that home NCAs cannot lean on speed alone. Because the recommendations applied to all NCAs rather than Malta alone, the review functions as bloc-wide guidance.

Centralised Supervision and ESMA’s Expanding Role

• The European Commission has proposed centralising supervision of CASPs within ESMA, moving it away from national authorities, a development cited in BBVA’s one-year MiCA review (published 24 December 2025).
• The proposal lands on top of the PRC’s recommendations to all NCAs on business growth, conflicts of interest, governance and intragroup arrangements, ICT/DORA, and Web3 and decentralised products, areas the peer review identified as authorisation pinch-points.
• ESMA’s existing role includes publishing the list of Article 93 designated NCAs.
• ESMA’s Board of Supervisors launched the MFSA peer review in April 2025.
• The peer review report’s “to all NCAs” framing of its authorisation recommendations effectively functions as a co-ordination channel already, even before any centralisation legislation.

Why it matters: The Commission’s centralisation proposal would shift CASP supervision from national authorities into ESMA, addressing the cross-border co-ordination that the MFSA peer review flagged. For applicants, that would mean one set of expectations and one ongoing supervisor, a structural change as large as MiCA itself.

Will MiCA supervision move to ESMA?

The European Commission has proposed centralising supervision of CASPs within ESMA, moving it away from national authorities. The proposal is a draft and would require legislative action through the EU Council and Parliament before taking effect. National regulators still hold MiCA supervisory power day-to-day, and the existing peer review and Board of Supervisors coordination structures continue to apply.

MiCA Scope Boundaries and Excluded Crypto-Asset Types

• MiCA regulates 3 crypto-asset types: electronic money tokens (EMTs), asset-referenced tokens (ARTs), and other crypto-assets (utility and other non-EMT, non-ART tokens).

The regulation carves out several categories. Unique non-fungible tokens sit outside scope, though NFTs issued as part of a series or collection can still fall within it. Non-transferable tokens such as loyalty-scheme points are excluded, as are crypto-assets already captured by existing financial-services law, including MiFID financial instruments, derivatives, and transferable securities. BBVA notes that MiCA carries a built-in mandate for the European Commission to report on DeFi, lending, and NFTs not currently covered, signalling a likely scope expansion.

Enforcement, Wind-Down Plans, and the Non-Compliant Register

• ESMA’s Q1 2025 register listed 15 non-compliant entities, all reported by Italy’s CONSOB.
• ESMA expects CASPs not yet authorised under MiCA to “have orderly wind-down plans in place ready for implementation ahead of the end of the remaining transitional periods”.
• The same December 2025 statement reminded CASPs to have implemented “orderly wind-down plans for the services they provided in Member States in which the transitional period is over”, not only those approaching the deadline.
• NCAs are reminded to “treat ‘last minute’ applications for authorisation under MiCA with considerable caution and assess their compliance with MiCA, upholding the same standard as for any other”.
• ESMA reminded users that it is “important to check in the ESMA Interim MiCA Register” that the CASP entity of which they are clients are authorised to provide crypto asset services under MiCA.

Crypto firms preparing for MiCA enforcement timelines can compare their compliance setup against CoinLaw’s MiCA compliance requirements stats and benchmark against the US crypto enforcement data framework that applies on the other side of the Atlantic.

Conclusion

MiCA’s first year cut the EU’s crypto-asset service provider count from over 3,000 legacy registrations to 102 fully authorised firms, with 30 stablecoin issuers and 12 credit institutions inside the new register.

The transitional regime closes on 30 June 2026, the PSD2 authorisation deadline for EMT-transacting CASPs falls on 2 March 2026, and ESMA’s MFSA peer review has recommended NCAs pay particular attention to business growth, conflicts of interest, governance and intragroup arrangements, ICT/DORA, and Web3 products. Firms that adapted early to the layered compliance schedule (stablecoin service restrictions, ICT and DORA scrutiny, intragroup governance audits) are now operating with the cleaner regulatory standing the regime promised.

The next milestone is structural: the European Commission has proposed centralising CASP supervision within ESMA, moving supervision away from national authorities, and reshaping the home/host friction that the peer review identified. For applicants in the pipeline, the rulebook is now public, and the data is now traceable to the ESMA register; the consolidation MiCA was designed to produce is measurable, ongoing, and accelerating into 2026.