The state of EU crypto-asset service provider licensing — 2026 mid-year report
We are now eighteen months into MiCA full application. The transitional windows in most member states have either closed or are within weeks of closing. The CASP register has filled in substantially. National regulators have published guidance, enforced actions, and refined their interpretations. This essay is a mid-year 2026 report on where things actually stand, written for retail investors, comparison-platform operators, and crypto-firm compliance teams who need a current picture rather than a forecast from 2024.
Corrections
- Corrected against ESMA's interim MiCA register and its list of transitional periods. Nexo and Bitget Europe were named as MiCA-licensed and neither is in the register; Nexo does not passport via CySEC. Germany's transitional period was 12 months, ending 30 December 2025, and France's 18 months, to 1 July 2026: the report had them the other way round. Coinbase's MiCA authorisation is Coinbase Luxembourg S.A.'s, from the CSSF, not Coinbase Germany GmbH's. Binance withdrew its Greek application in June 2026; the report said it withdrew applications across member states in 2024–2025. And the Travel Rule has applied since 30 December 2024, not from 1 July 2026.
Every correction is also listed in the public corrections log.
The baseline: full application has held
The biggest takeaway from eighteen months of MiCA full application is the absence of major surprises. The regulation has worked broadly as designed. Major exchanges have either obtained authorisation, partnered with EU-licensed entities, or withdrawn from EU retail markets. The bifurcation between MiCA-licensed and non-MiCA providers in EU consumer-facing markets has become operationally clear.
The headline-level licensed CASP count is now substantial. Across the EU, several dozen authorised CASPs are operational across spot trading, custody, brokerage, payment services, lending, and stablecoin issuance. Most of the names retail investors recognise — Bitpanda, Bitvavo, Kraken, Coinbase, Crypto.com, OKX, Bybit — hold a MiCA authorisation in an EU member state with passporting rights (ESMA's interim register, read 10 October 2026). Nexo and Bitget are not in that register.
The operational reality of passporting has also held. A CASP authorised in Ireland (Kraken via CBI) can serve a German customer without separate German authorisation. A CASP authorised in Austria (Bitpanda via FMA) can serve a Spanish customer. The passporting fiction is functioning as actual passporting — at least for the categories of services the major players offer.
Country-by-country snapshot
Germany. Germany chose a 12-month transitional period, which ended on 30 December 2025 (ESMA's list of grandfathering periods). BaFin-authorised CASPs include Bitpanda Asset Management, Trade Republic, N26 and Crypto Finance (Deutschland); Coinbase serves German customers under its Luxembourg authorisation, and Bitpanda under its Austrian one as well. The Kryptowertpapier-issuance side is also developing, with several institutional tokenisation projects under BaFin oversight.
France. France allowed the full 18-month transitional period, to 1 July 2026, by which PSAN-registered firms had to hold a MiCA authorisation or stop serving French retail. The notable French CASPs include several spot-trading-focused firms with broad French-language presence.
Netherlands. One of the shortest transitions (six months, ended 30 June 2025, as in Finland, Hungary, Latvia, Poland and Slovenia). The AFM authorises CASPs, and Bitvavo holds particular prominence.
Ireland. The Central Bank of Ireland (CBI) has positioned itself as a preferred passporting jurisdiction for crypto-asset service providers seeking EU access via an English-language regulatory environment. Kraken EU is the most-visible CBI-licensed operator; several institutional-focused crypto firms have followed.
Malta + Cyprus. MFSA + CySEC remain active passporting jurisdictions. Crypto.com, OKX and Gemini passport from MFSA authorisations; Revolut's crypto service from a CySEC one. The jurisdictions retain strong crypto-specific licensing track records.
Spain, Italy, Portugal. Joint securities + central-bank supervision models. Transitional windows remain in effect (typically through mid-2026 for previously-registered firms). Limited domestically-headquartered MiCA-licensed CASPs; most retail flow goes to EU-passported alternatives.
Notable departures and adjustments
Binance's position in the EU has been the most significant industry development. It withdrew its MiCA application in Greece in June 2026, before the transitional period ended, and suspended services in several EU countries, France among them, from 1 July 2026 (Euronews, 25 June 2026); it says it will reapply through another member state. No Binance entity is in ESMA's register as read on 10 October 2026.
Several mid-sized non-EU exchanges have similarly withdrawn from active EU retail marketing rather than complete authorisation. The cost-benefit calculation for smaller players — whose EU revenue did not justify the authorisation cost — has favoured strategic withdrawal in multiple cases.
Stablecoin issuance has been notably slower to develop in the EU than expected. MiCA Titles III + IV requirements (e-money institution authorisation for euro-denominated EMTs, etc.) have proved a higher bar than many issuers anticipated. No major euro-denominated stablecoin has achieved volumes comparable to USDC or USDT under EU authorisation.
DeFi-front-end question remains open. Pure decentralised protocols are outside MiCA scope by design. Centralised front-ends (uniswap.org, app.aave.com, etc.) operating in or marketing to EU users face complex assessment. National regulators have been cautious in their enforcement so far, but the regulatory perimeter on this question continues to tighten.
What the second half of 2026 looks like
The defining event of H2 2026 is the European Commission's first MiCA review, due by 30 December 2026 per Article 140. The review will assess MiCA's functioning across stablecoin supervision, CASP authorisation, retail protection, and adjacent topics including DeFi treatment and NFT clarifications.
ESMA's harmonised supervisory framework report is expected mid-2027 but groundwork is being laid in 2026. National-implementation divergences (transitional period lengths, supervisory practices, interpretation of "fully decentralised") are being catalogued.
DAC8 reporting begins for transactions in 2026, with first reports due January 2027. The interaction with MiCA is operational rather than legal — MiCA-licensed CASPs are the entities that will report under DAC8. The combined effect closes the information gap for crypto taxation in the EU.
The Travel Rule (Regulation (EU) 2023/1113) has applied to crypto-asset transfers since 30 December 2024, and the longest national transitional periods closed on 1 July 2026. The combined operational impact on CASPs is meaningful: KYC, transaction monitoring, MiCA conduct rules, DAC8 reporting, Travel Rule data attachment — all simultaneous obligations.
For retail investors: the EU CASP landscape is now substantially clearer than at any point since 2018. Choosing a MiCA-licensed provider is no longer difficult; verifying MiCA status takes seconds via the ESMA register. The next year's evolution will be incremental rather than structural.
What this means for comparison platforms
Comparison platforms serving EU retail users now operate in a fundamentally different environment than in 2023. The MiCA-licensed/non-licensed distinction is no longer ambiguous — it can be verified per-provider against the ESMA register and national CASP registers. The audience asking about MiCA status is sophisticated. The regulatory pressure on misleading marketing of non-licensed providers has tightened.
For platforms like ChainChoice, this is a structural opportunity. The pre-MiCA comparison landscape was opaque enough that distinguishing between editorially-rigorous and payola-driven platforms required reader expertise the average retail investor didn't have. Post-MiCA, the basic facts (who is licensed, where, with what scope) are externally verifiable. A platform that builds its recommendations on these verifiable facts can be evaluated by readers in ways that weren't possible before.
The inverse is also true. Platforms still operating on the old "vague claims + universal-affiliation rankings" model now face an audience that can — and increasingly does — check.
Eighteen months into full MiCA application, the EU crypto-asset service provider universe is more coherent than at any point in the previous decade. The compliance baseline is verifiable. The provider population is bifurcated cleanly between MiCA-licensed (recommendable to EU retail) and non-licensed (not). The retail audience is sophisticated enough to apply the distinction. For comparison platforms, this is the most useful environment to operate in since the category began. For retail investors, it is the safest moment to be choosing a crypto provider. The architectural shift is real, and 2026 H2 will see it continue to settle into the new operational baseline.
Mathias Siemonsmeier. Mathias Siemonsmeier, Founder of ChainChoice. Mathias spent five years in banking and fintech before moving into blockchain research. He founded ChainChoice to compare crypto and onchain products on published, verifiable criteria, and he writes and reviews its rankings and guides. He writes about editorial integrity in decision-support platforms, cryptographic provenance for editorial decisions, and the architectural — not policy — approach to ranking-system independence.