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Countdown to MiCA Implementation: Overview of Licensed Entities Trends in Europe by 2025

Original authors: Huang Wenjing, Yan Xuesong

Looking back from early 2026, 2025 was the year when the crypto world was reshaped — Bitcoin hit new highs, key projects were successfully implemented, and the market steadily grew amidst rationality. Meanwhile, a deeper transformation came from the maturation of global regulations: stablecoins, licensing, and anti-money laundering rules were clearly established in multiple countries, injecting much-needed certainty into the industry.

Among these, the EU's MiCA regulation was fully implemented by the end of 2024 and entered its crucial implementation phase in 2025. This unified framework covering 27 countries served as a beacon, both defining compliance boundaries and illuminating new growth opportunities. When the transition periods in several countries officially ended in the fourth quarter of last year, the European market had already undergone profound changes and restructuring — 68 newly licensed institutions entered the market, traditional VASPs successfully transformed into CASPs, and new powerful players emerged.

36-month MiCA timeline for licensed entities providing crypto-asset services

(Source: Latest guidance from the ESMA official website)

This article will analyze the future development direction of traditional supermarkets (large KA hypermarkets) from two dimensions: Latest regulatory updatesEmbark, organizeTypes and characteristics of newly licensed institutions, interpretation of different approaches across countries, revealing the next phase of industry evolution.Help you navigate through the changes and gain insights into the true pulse of the European market.

1. Logic of service licensing: License ≠ omnipotence

The core of the MiCA regulation is to establish a unified entry threshold for crypto-asset service providers across Europe. Licensed entities approved by National Competent Authorities (NCAs) can legally operate throughout the EU via the 'EU Passport' mechanism. According to MiCA, licensed institutions can provide10 categoriesof services, includingcustody, operating trading platforms, exchange, order execution, investment adviceetc.

However, the scope of licensing varies significantly depending on the service combination selected at the time of application. Common business logic includes:

Platform-based services：Operational trading platforms typically require complementary services such as custody, exchange, and order execution to support a complete trading cycle.

Asset management servicesPortfolio management often needs to be integrated with order execution to enable dynamic rebalancing of managed assets.

Standalone servicesCustody, investment advice, and transfer services can also exist independently, catering to institutions that focus on niche areas.

It is important to note that the above service combinations are not mandatory and only represent a typical business logic. Large integrated platforms, such as Coinbase and Kraken, usually apply for multiple services because they can support each other to create a closed-loop user experience. However, smaller or specialized institutions can focus on a single service, such as custodial wallets, standalone advisory, or cross-chain bridges, which is perfectly acceptable.

In practice, various business combinations mainly appear in scenarios aiming to provideone-stopservices. If an institution wishes to operate a very specific business or has budget constraints, it can avoid relying on other services entirely, saving both money and effort. This also means that when an institution claims to hold a MiCA license, it should not be assumed that it can 'do everything.'

Understanding this point helps us view the strategies and capabilities of newly licensed institutions more objectively, while clarifying the following common misconceptions:

Does holding a MiCA license mean full compliance and no risk?Not necessarily. The license simply means that the entity can operate within its authorized scope, without excluding other operational and market risks.

Does an institution's promotion of having a MiCA license equate to possessing all service qualifications?Not necessarily. Its actual business may be limited to specific areas such as custody, exchange, or advisory services.

Does an institution offering portfolio management services necessarily have the ability to execute trade orders?Not necessarily. The institution may achieve trade execution through cooperation with third-party licensed service providers.

2. Key characteristics of newly licensed entities in Q4

In the fourth quarter of 2025, there were 68 newly licensed institutions, directly resulting fromthe end of the MiCA unified regulatory transition period in most member states.Previously, institutions relying on existing VASP frameworks in various countries are now facing"either obtain a license or exit the market"the final deadline, triggering a wave of concentrated compliance applications and transitions.

This phenomenon is both a natural outcome of the regulatory transition period and reflects strategic choices by institutions adapting to new regulations—whether international giants or local upstarts, all have completed their status conversion before the deadline, showcasing the distinct trend of layered evolution and ecosystem integration within the cryptocurrency industry as it moves toward standardization.

Significant increase: A total of 133 licensed entities, with 68 newly licensed entities added in the fourth quarter—showing remarkable growth, far exceeding the previous three quarters.

Service concentration: Services mainly focus on custody, transfer, and exchange, with a low proportion of entities holding full-service or multi-service licenses, while narrow authorization accounts for a high proportion.

Regional concentrationApproximately 60% concentrated in Western Europe (42 entities across Germany, France, the Netherlands, Austria, and Ireland combined), with Eastern Europe and EEA countries (Liechtenstein) beginning to show increased activity.

Nordic riseThe Nordic region has seen a sudden emergence: Finland increased from one entity in Q4 to five, while Sweden went from zero to having a presence.

Cross-border activityHigh passport utilization rates, with most institutions covering more than ten EU countries.

Overall, these new entities can be roughly divided into three categories:Giants, mid-tier players, and newcomers. This classification is based on their size, market influence, and breadth of services.

1. Giants: Leading market integration

Among the licensed institutions in the fourth quarter, the entry of industry giants is particularly noteworthy. These institutions typically tend toapply for permissions across more than five service categoriesto build a 'one-stop' platform coveringcustody, trading, and exchangeand other multifunctional services, quickly responding to the needs of the EU's unified market.

British digital bank Revolut obtained its license in Cyprus, offering six services including custody, trading platform operation, and fiat-to-crypto exchange, potentially introducing over 50 million users into the crypto space. Global exchange KuCoin secured permits for five services in Austria, encompassing custody, exchange, and underwriting core functions; meanwhile, Blockchain.com (Malta) and crypto bank AMINA EU (Austria) also entered the market as integrated service providers.

Characteristics:

Economies of scale: These licensed entities typically enjoy international or continental-level reputations, with large user bases, substantial capital, and mature technologies. They are expected to rapidly expand operations and capture shares in the EU’s unified market.

Internal integration: Market entry is often achieved by establishing subsidiaries, strategically avoiding external risks.

2. Midstream: The Power of Steady Progress

Operating alongside the giants are some mid-tier licensed entities, which typically have a stable and moderate-sizeduser baseandmature technology in certain areas, previouslyrelying on national-level VASP registration。

For example, Bitonic B.V., founded in 2012, is the oldest and largest local Bitcoin broker in the Netherlands. It has long focused on the domestic market, offering reliable and stable services with almost no major security incidents, earning the trust of individual customers. On November 21, the company obtained its MiCA license, allowing it to provide custody, exchange, order execution, and transfer services. This represents the standard development path for mainstream platforms in the Netherlands—most other newly licensed institutions in the country also possess these types of permissions.

Another typical case is Renta 4 in Spain, a long-established bank currently undergoing a transformation. With a moderate scale and good reputation in traditional investment fields, it was recently approved to offer custody and transmission services.

The advantage of such mainstream institutions lies in their deep understanding of the local market. Typically, they choose a moderate range of service offerings under controllable compliance costs, avoiding direct competition with large international platforms. As a result, they become trustworthy options for ordinary users.

Characteristics:

Expand after deep cultivation in the local market: Single-country service, or gradually moving towards multi-jurisdictional licensing.

Medium service portfolio: 3-5 types of services.

Lower risk: Already has a compliance foundation with high user loyalty.

3. New players: Rising stars

Emerging or localized licensed entities are often smaller in scale. The emergence of these institutions gives the impression of rushing to meet the MiCA deadline, almost like a last-minute 'homework completion' behavior.

However, they also fill some local gaps. Typical examples include six local banks in Germany (Volksbank Mittlerer Schwarzwald eG, Hannoversche Volksbank eG, VR TeilhaberBank Metropolregion Nürnberg eG, etc.), all of which were approved in December but can only provide order execution services. The advantage of these emerging institutions lies inflexibility and cost advantages。

Characteristics:

Narrow-domain services: Focused on addressing specific pain points in the local crypto market.

Potential Risks: Small user base, low business volume or not yet operational, easily becoming future acquisition targets or struggling to fulfill compliance obligations long-term.

Institutional styles vary significantly across regions, reflecting differences in local economies, user habits, and regulatory environments. Western European countries such as Germany, France, and the Netherlands dominate new additions, while Eastern European nations like Slovakia, Slovenia, and Latvia focus more on retail-oriented services.

1. Regional Differences:

Eastern Europe: Strong retail focus, concentrated compliance push

In Q4, a total of 10 licensed institutions were added in Eastern European countries, primarily in Slovakia, Slovenia, and Latvia. These institutions generally emphasize retail service portfolios, commonly offering bundled services such as 'custody + exchange + transfer,' with fewer involved in operating trading platforms. For instance, institutions like FUMBI in Slovakia hold over five service authorizations, while BlockBen in Latvia focuses on niche markets like 'gold tokenization.'

This phenomenon is mainly due to:

Concentrated compliance conversions before the end of the transition period;

Local markets dominated by retail investors, with relatively low institutional capital participation;

Lower compliance costs compared to Western Europe, attracting numerous local startups and small-to-medium-sized institutions;

Limited regulatory approval resources led to a Q4 focus on clearing the backlog of applications.

New licensed entities in Western European countries: Examples include France and Germany.

Germany and France are the main representatives of new institutions in Western Europe. Germany added 16 institutions, most of which are traditional banks offering only single order execution or transmission services; France added five, among which the crypto division under Societe Generale, one of France's 'big three' banks, applied for only two services—custody and transfer—highlighting a 'narrow compliance' approach.

Despite Western Europe's mature financial infrastructure and institutional capital, high compliance costs have prompted many institutions to streamline their service scope to control initial investment. This also indicates that activity in the crypto market does not always align perfectly with regional economic scale.

EEA countries - Liechtenstein

The emergence of this new name is eye-catching, with registered licensed entities in the country showing a preferencefor a total of two entities,both of which focus their services around custody, giving an impression of a 'small but premium' high-end positioning. The reason lies in itsneutral and low-tax environment.AttractPrivate bankingas well as asset management. Additionally, even though Liechtenstein is not a member of the EU, MiCA still applies.High passport value；Niche and high-end marketwith investors mostly being professional players such as family offices.

2. Industry consolidation trend: Invisible restructuring rather than explicit M&A

Although there were no significant M&A cases in the fourth quarter, the entire industry has actually been quietly consolidating. Many giants have chosen to establish their own EU subsidiaries instead of acquiring others, allowing full control over operations while avoiding the complexities of due diligence and approval risks.

The report shows that small institutions have already been acquired by mainstream platforms throughout 2025.In the fourth quarter, it was more about everyone 'running their own race' - independently applying before the transition period ends.

Based on incomplete statistics and actual data feedback, the current success rate for MiCA applicationsis not as high as expected., regulatory bodies continue to prioritize substance in their review process:A license isn't built from a stack of application materials but is the natural outcome of a genuine and reliable business model.

Yes. investorsTo say,The MiCA license is not a permanent 'talisman', as a license is only the starting point, not the endpoint. Obtaining a license doesn’t equate to having a fully mature business; it’s important to scrutinize whether specific services are offered and which countries the passport covers to ensure confidence in its use.

Yes.Operators, in certain countries or regions,an increase in new entities does not necessarily mean lower regulatory difficulty, but may instead reflect existing service providers’tailor-made operational strategies or temporary measures。

for those preparing for the MiCA licenseThe actual expenses are also not to be underestimated. Applicants might as well ask themselves: do I really need this license? A proactive approach to compliance is commendable, but understanding one's position and long-term goals may be a wiser move. Hopefully, this article can help you identify opportunities in the European crypto market amidst changes.

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