08/01/26
One year after its entry into force, the Markets in Crypto-Assets Regulation (hashtag#MiCAR) has fundamentally reshaped the digital asset landscape in Europe. As the first comprehensive regulatory framework for crypto-assets in the EU, MiCAR now requires a license for all Crypto-Asset Service Providers (CASPs) to operate legally within the union.
Here is the current state of the market and the critical regulatory shifts you need to know:
1. The Leaderboard: 138 Licensed CASPs 📊
Currently, there are 138 licensed companies providing a total of 467 authorized services across the EU. The market shows a heavy geographical concentration, with Western Europe dominating 70% of the leaderboard.
• Germany leads the pack with 42 licenses.
• The Netherlands follows with 22 licenses.
• France holds 11 licenses.
2. Navigating Transitional Periods 🕒
Compliance requirements vary significantly by country due to different transitional timelines. It is vital for firms to know where they stand:
• Transitional Period Ended (⛔): In countries like Germany, the Netherlands, Ireland, Austria, and Finland, the "grace period" has ended. A full MiCAR-compliant license is now mandatory to operate.
• Active Transitional Period (🟢): Countries including France, Malta, Cyprus, Spain, and Italy have an active transitional period lasting until June 30, 2026, allowing firms more time to finalize their compliance.
• Uncertain Status (🟠): In Belgium, Poland, and Portugal, the transitional status remains unknown or has been postponed.
3. Traditional Finance Steps In 🏦
A major observation of the first year is the professionalization of the sector. More than 60% of MiCAR licenses have been secured by traditional financial institutions. There are now 30 banks holding crypto licenses, with 18 of those located in Germany alone. This indicates that crypto is no longer a niche market but a core component of the modern financial system.
4. Implementation Challenges ❌
Despite the framework's success, implementation is not uniform. For example, experts expected licenses from Denmark months ago, yet none have been issued. In Poland, both the president and parliament have recently ruled against the implementation of certain aspects of the framework, highlighting that legal hurdles still exist at the national level.
Compliance is the only path forward in the EU crypto market. 🏛️
Whether you are a startup or an established financial institution, navigating the complexities of MiCAR is essential for long-term operational success.
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Melisa Dogan