The MiCA Regulation (Markets in Crypto-Assets), the EU’s first common set of crypto rules, promised to replace a patchwork of national regimes with one regulatory framework for crypto assets and the crypto asset service providers (CASPs) that handle them. When we first assessed its impact in spring 2025, every number was a forecast. On 1 July 2026 the last transitional period expired, the old national licences lapsed, and the EU crypto market became, in legal terms, the list of entities in the ESMA register.
This article measures the 2025 forecasts for the European crypto industry against what actually happened: how many crypto companies hold a MiCA licence and who they are, what became of Estonia and Poland, why Binance left, how ESMA and the ECB have used their new powers, and what the Commission’s review of the regulatory framework may change. It is an opinion piece by the Eesti Firma team, not a neutral summary.
MiCA Timeline: Key Dates and the 1 July 2026 Deadline
Regulation (EU) 2023/1114 was applied in stages: stablecoin rules first, the CASP licensing regime six months later, and a grandfathering window of up to 18 months for existing virtual asset service providers (VASPs) that member states could shorten but not extend.
| Date | Event | What it meant for providers |
|---|---|---|
| 31 May 2023 | MiCA adopted by the European Parliament and Council | Two-year preparation window opens |
| 30 June 2024 | ART and EMT rules apply | Stablecoin issuers need EU authorisation; non-compliant tokens start leaving EU platforms |
| 30 December 2024 | Full application to CASPs and other crypto assets | New entrants apply to a national competent authority under MiCA; old national licences stop being issued |
| 20 May 2026 | Commission opens the MiCA review consultation | Scope, stablecoins, CASP rules and DeFi reopened; responses due 30 September 2026 |
| 1 July 2026 | End of the maximum transitional period | National VASP registrations void; unauthorised providers must wind down EU activity |
| 30 June 2027 | Commission report under Article 140 due | Possible legislative proposal to amend the regulation |
The MiCA transitional period was never extended. ESMA said as much in April 2026 and on 23 June 2026 issued a public statement ordering unauthorised providers to stop onboarding EU clients, cease marketing and limit crypto-asset services to closing or transferring positions. The review consultation, by contrast, opened six weeks before that deadline: the Commission did not wait for the regime to settle before asking whether it works.
MiCA in Numbers: How Many Crypto Companies Are Licensed in 2026
The baseline for crypto licensing in Europe before MiCA comes from the Coincub Europe Crypto Report 2025: more than 3,100 registered crypto companies across the EU at the end of 2024, with Poland alone hosting around 1,400 and Lithuania over 530, while Germany, Austria and Belgium had barely a dozen between them. Cheap registration and minimal checks were the product, and the regulation was designed to end exactly that.
The forecast in 2025 was that three-quarters of those providers would lose their status. It was too optimistic. Trackers reading the ESMA interim register counted around 40 MiCA-licensed CASPs in autumn 2025, roughly 180 by April 2026, just over 200 on the day the transitional period closed, and between 320 and 340 authorisation records by mid-September 2026 as national supervisors cleared their backlogs. Against 3,100 pre-MiCA registrations, attrition in the European crypto market is above 90 per cent.
| Spring 2025 forecast | Position in September 2026 |
|---|---|
| Three-quarters of VASPs lose their status | More than nine in ten pre-MiCA registrations did not become a CASP authorisation |
| 100–130 MiCA authorisations by end of 2025 | Around 40 by autumn 2025; the register passed 300 only after the July 2026 deadline |
| Licensing takes six months or more | Twelve to twenty-four months at BaFin; smaller authorities are faster but still exceed six months |
| Compliance costs rise several-fold | Advisory budgets of €80,000–200,000 reported in Germany; €40,000–60,000 is the floor elsewhere |
| Poland loses its lead | Poland has no competent authority at all; Germany, the Netherlands, France and Malta lead the register |
The map has inverted: Germany, with eleven registered providers under its old regime, now holds around 60 CASP licences — a fifth of the EU total — followed by the Netherlands, France, Malta, Cyprus and Ireland. On the stablecoin side there are about twenty authorised e-money token issuers and not one asset-referenced token issuer.
The composition of the MiCA-licensed exchanges and custodians matters more than the count. The July 2026 additions to the register include Standard Chartered, Ripple Payments Europe, Clearstream, Commerzbank and a string of German cooperative banks, alongside brokers such as Trading 212 and Interactive Brokers. Of roughly 320 entries, only 26 are permitted to operate a crypto exchange or trading platform. The harmonised European regulatory framework did not create a competitive crypto-native industry. It created an on-ramp through which traditional financial institutions absorbed the regulated part of the market.
MiCA in Estonia and Poland: Two National Outcomes
Two former licensing hubs show what a harmonised EU crypto market means in practice when national policy diverges.
Estonia: from 641 FIU licences to one MiCA CASP licence
Estonia’s clean-up started before MiCA. When the Financial Intelligence Unit began tightening the sector in mid-2021, 641 licences were in force; by the start of 2026 there were 36. On 1 July 2026 the FIU declared every remaining licence void, and Finantsinspektsioon confirmed that by that date it had granted exactly one Estonian crypto licence under MiCA — Lightspark Payments Europe AS — with AS LHV Pank and the investment firm Lightyear Europe AS entitled to offer crypto services under their existing licences. Everyone else serving Estonian clients does so on a passport from another EEA supervisor.
The transfer of supervision from the FIU to Finantsinspektsioon and the MiCA compliance duties of an Estonian CASP are covered separately. What the numbers add is perspective: a jurisdiction once synonymous with crypto licensing entered the MiCA era with fewer authorised providers than most of its neighbours — the end state of a decision, taken in 2021, to put reputation ahead of volume.
Operating without authorisation in Estonia
Finantsinspektsioon reminded former FIU licence holders in March 2026 that providing crypto-asset services after the transitional period without a MiCA authorisation is a criminal offence under § 372 (4) of the Penal Code, not an administrative lapse. Providers that missed the deadline must wind down, transfer clients to an authorised CASP or apply through the Estonian crypto licence procedure before resuming activity.
Poland: 1,400 VASPs and no competent authority
Poland, which hosted nearly half of all EU registrations, still has no national competent authority under MiCA. The act that would have given the Polish Financial Supervision Authority (KNF) licensing powers was vetoed by the President in December 2025, February 2026 and June 2026, and the Sejm’s latest attempt to override the veto, in September 2026, fell short. As the KNF statement issued before the deadline makes clear, Polish entities lost the right to provide crypto-asset services on 1 July 2026 and cannot even file an application at home. The only lawful route into the Polish market is a CASP licence obtained elsewhere and passported in. A veto framed as protection from overregulation has become an export subsidy for Lithuania and the Czech Republic.
Binance and Unlicensed Crypto Exchanges After 1 July 2026
The sharpest test of how MiCA treats a large non-EU platform came in June 2026. Binance, still handling well over 40 per cent of global spot volume, withdrew its application from the Hellenic Capital Market Commission on 24 June 2026, six days before the deadline and shortly after reports that the regulator was heading for a rejection on fit-and-proper and anti-money-laundering grounds; earlier approaches in Ireland and Latvia had also failed. From 1 July the exchange stopped onboarding EU clients and suspended new spot orders, deposits and earn products across the bloc, while announcing a fresh application in France.
There are two readings of this episode, and both are correct. On one, EU crypto regulation worked as intended: a supervisor declined to license an applicant whose record it did not trust, and the market absorbed the shock without a crisis. On the other, the world’s largest exchange now serves European users, if at all, through the narrow reverse solicitation exemption and non-EU entities, outside every MiCA safeguard — precisely the outcome the regulation claims to prevent. For users the practical rule is simple: a crypto asset service provider not listed in the ESMA register holds no MiCA licence, and digital assets held there fall outside its client-protection rules.
ESMA and MiCA Supervision: From Warnings to Direct Oversight
ESMA’s public line has not moved since Executive Director Natasha Cazenave warned in April 2025 that crypto assets remain speculative under the new regulatory framework and that MiCA does not remove the underlying risks. What has changed is the institutional ambition behind it. National licensing practice diverged quickly: ESMA’s July 2025 peer review found that the Maltese regulator had authorised a CASP with material issues unresolved, and the French, Italian and Austrian supervisors publicly called for centralised supervision to stop regulatory arbitrage. On 4 December 2025 the Commission answered with its Market Integration and Supervision Package, which proposes to transfer the licensing, supervision and enforcement of all crypto asset service providers from national authorities to ESMA. ESMA welcomed the proposal the same day.
As of September 2026 the package is in the ordinary legislative procedure — the European Parliament’s ECON committee published draft reports in June 2026 and trilogue negotiations are expected to run into 2027. Nothing in it changes the requirement to hold a national CASP licence today. But a company that has just spent a year and a six-figure sum on a licence from Finantsinspektsioon or the Bank of Lithuania should expect a second migration, to a Paris-based supervisor with no track record in overseeing several hundred crypto firms, within a few years — a second bill the crypto industry was never shown.
MiCA and Stablecoins: USDT, USDC and the ECB
For crypto asset service providers the stablecoin question is commercial, not academic. MiCA created the e-money token as the legal category for regulated stablecoins in Europe; the European Central Bank has made sure it stays small. In a speech on 8 May 2026 President Christine Lagarde argued that private stablecoins by their nature cannot anchor the monetary system, that the case for euro-denominated stablecoins is weaker than it appears, and that Europe should build tokenised settlement on central bank money — with a digital euro targeted for 2029. Two weeks later the ECB warned finance ministers that euro stablecoin issuance could drain retail bank deposits.
The concrete battleground is multi-issuance, the model under which a global stablecoin such as USDC is issued jointly by EU and non-EU entities and remains fungible across both. The European Systemic Risk Board, chaired by Lagarde, called for a ban; the European Parliament voted 390 to 86 on 9 July 2026 to keep multi-issuance with safeguards; the review consultation asks the question openly. Meanwhile USDT still has no EMT authorisation and has been removed from order books at most MiCA-licensed crypto exchanges. Dollar tokens account for roughly 99 per cent of a market above $300 billion, euro tokens for a fraction of one per cent, and a consortium of European banks operating through the Dutch entity Qivalis is only now preparing a MiCA-compliant euro stablecoin for the second half of 2026.
Banking Access for MiCA-Licensed Crypto Companies
A licence has not solved debanking. Authorised crypto asset service providers still report that EU commercial banks decline accounts outright, impose prohibitive fees or minimal transfer limits, and that counterparties reject payments from IBANs in certain member states over perceived anti-money-laundering risk. The most quantified evidence is British: the 2025 “Don’t Bank On It” report by the Startup Coalition, Global Digital Finance and the UK Cryptoasset Business Council found that only 14 per cent of crypto and fintech firms could open and keep an account with a major bank. In the United States debanking became a political question, with congressional reports, regulatory admissions and a Federal Reserve proposal for limited master accounts. In Europe there is still no public data, no consultation on IBAN discrimination and no regulator that treats bank access for a licensed crypto business as its concern. A licence that cannot be banked is a licence in name only.
MiCA vs the United States: GENIUS Act and CLARITY Act
In spring 2025, US policy on digital assets consisted of executive orders and a promised reserve. Since then Washington has legislated: the GENIUS Act, signed on 18 July 2025, gave payment stablecoins a federal framework, and the Digital Asset Market Clarity Act — the market structure bill dividing jurisdiction between the SEC and the CFTC — passed the House in July 2025 and cleared the Senate Banking Committee on 14 May 2026, with a floor vote still pending. The US spent 2021–2024 regulating by enforcement and is now writing statute; the EU spent 2020–2024 writing statute and is now regulating by enforcement. For a crypto founder choosing where to build in 2026, the American trajectory reads as opening and the European one as narrowing, and venture capital has drawn the obvious conclusion.
What MiCA Means for Crypto Businesses in 2026
Before MiCA a start-up could register in Poland for a few thousand euros and be operating within weeks. A MiCA licence application now takes well over six months at the fastest supervisors and up to two years at BaFin, requires a full policy set from custody to DORA resilience, and consumes advisory budgets from around €40,000 in the leaner jurisdictions to €80,000–200,000 in Germany, before capital, supervisory fees and resident compliance staff. The single licence does deliver access to a market of roughly 450 million people through EU passporting, and for a well-funded crypto exchange that trade is rational. For a two-founder Web3 project it is not, and those blockchain start-ups have left, merged or gone white-label.
Three routes into the EU market after the deadline
Apply for a CASP authorisation under MiCA in a member state with a functioning procedure; operate under an authorised CASP’s licence in a white-label or agency model, bearing in mind that custody cannot be outsourced to an unauthorised entity; or serve EU clients only on their own exclusive initiative under the reverse solicitation exemption, which ESMA interprets narrowly and which permits no marketing of any kind.
MiCA Review 2026: Is a “MiCA 2” Coming?
On 20 May 2026 the Commission opened a targeted consultation on the review of MiCA under Articles 140 and 142 — 86 questions on scope, stablecoins, CASP rules and the boundary between regulated and unregulated activity, with the deadline extended to 30 September 2026. The Commission must report by 30 June 2027 and may attach a legislative proposal. The questions are the ones the industry has raised since 2024: the ban on interest for stablecoin holders, the treatment of DeFi, staking, lending and perpetuals, proportionality for smaller CASPs, and simplification. Our expectation for a MiCA 2 is recalibration rather than rewrite — proportionality for small providers, a settlement of the multi-issuance dispute with new safeguards, and some accommodation of tokenised deposits — with nothing in force before 2028.
Conclusion
Nearly two years after full application, the MiCA Regulation has delivered the one thing it promised unambiguously: a single legal perimeter. Inside it sit a few hundred authorised crypto asset service providers, an increasing share of them banks and brokers, passporting across the EEA. Outside it sit the thousands of registrations that did not convert, the largest exchange in the world, the Polish market and most of the crypto-native start-ups that made the European crypto industry interesting in the first place. In 2025 we concluded that Europe risked becoming not a leader in digital finance but the region with the highest regulatory constraints. The data since then do not soften that view. What has changed is that the constraints are now being challenged from inside — by a Parliament that overruled the ESRB on stablecoins and a Commission that reopened the file before the ink was dry.
There is also a conclusion that is rarely said aloud. For a well-capitalised provider with a working compliance function, MiCA is the best thing that has happened to its European business: most competitors are gone, new entry costs six figures and a year, the largest global exchange is outside the perimeter, and a single CASP licence passports into a market of 450 million people. The regulation was written as a rulebook; it functions as a moat. Whether that was the intention is a question for Brussels. For those who hold an authorisation, or are prepared to obtain one, it is simply the terrain — and it rewards the few who stayed.
