After the MiCA deadline: 204 authorised CASPs, and what happened to the other thousand

The Markets in Crypto-Assets Regulation's transitional window, the grandfathering arrangement that let firms registered under national crypto regimes keep trading while they pursued full authorisation, closed on 1 July 2026. ESMA has called on crypto-asset service providers that did not secure authorisation to wind down their activities in an orderly manner. After that date, serving EU clients without a CASP authorisation is not a compliance gap to be remediated. It is a breach of EU law.

CASPs holding full MiCA authorisation as at June 2026

204CASPs holding full MiCA authorisation as at June 2026

Share of previously registered firms that did not obtain a licence

~80%Share of previously registered firms that did not obtain a licence

EEA states reachable on a single passported authorisation

30EEA states reachable on a single passported authorisation

Attrition, not exodus

More than 1,200 firms held national registrations across the bloc before MiCA. Roughly 204 held a full CASP authorisation by June 2026: among them Kraken, Coinbase, Binance, OKX, Crypto.com and Bitstamp. The gap is often narrated as firms choosing to leave Europe. That reading is too flattering to everyone involved.

A meaningful share of the attrition is capacity. National competent authorities were asked to assess a multi-year backlog of applications against a new and untested standard, on statutory clocks, with supervisory teams that in several member states were being recruited at the same time as they were assessing. When the authorisation pipeline is the bottleneck, the observed outcome, most firms unlicensed, looks identical whether the cause is unfit applicants or an under-resourced regulator.

A licensing regime is only as fast as its slowest assessor. Throughput is a policy outcome, and it has to be designed for like any other.

The passport is the prize

A single CASP authorisation passports across all 30 EEA member states: the 27 EU countries plus Iceland, Liechtenstein and Norway, without separate national applications. That is the structural reason firms tolerated the cost and duration of the process, and it is the clearest lesson available to any jurisdiction designing a digital-asset regime outside the EU: the value of a licence is a function of where it is accepted, not of how demanding it was to obtain.

Meanwhile, the United States is regulating the instrument, not the venue

Europe authorised service providers. The United States has moved first on the asset. The GENIUS Act, signed on 18 July 2025, established the first federal framework for payment stablecoins: full 1:1 reserve backing in high-quality liquid assets such as cash and Treasury bills, and a prohibition on issuers paying any form of return to holders. Federal and state regulators were directed to issue implementing rules on issuer licensing, capital, custody and AML by 18 July 2026, with enforcement beginning in January 2027 across a stablecoin market of roughly $314bn.

Market structure is the unfinished half. The CLARITY Act, which would give the CFTC exclusive jurisdiction over spot digital-commodity markets, distinguish between categories of staking, and carve genuinely decentralised protocols out of registration, passed the House 294 to 134 in July 2025 and remained pending in the Senate through mid-2026. The contested point is a familiar one: banks want the yield loophole for stablecoin issuers closed, on the view that a yield-bearing dollar token competes directly with deposits.

Neither model is portable wholesale. Both assume a supervisory function that can absorb structured returns at volume and act on them, which is, again, the capability that decides whether a framework works, not the framework itself.