MiCA explained: the EU’s crypto rulebook

What MiCA is and what it covers

MiCA is an EU regulation, meaning it applies directly in every member state without national transposition. It replaced a patchwork of national registration regimes with one set of rules for crypto-assets that are not already covered by existing financial law. Tokenized shares or bonds, for example, remain under securities rules such as MiFID II.

The regulation sorts its subject matter into three groups:

• Crypto-asset service providers (CASPs). Firms that operate trading platforms, provide custody, execute or route orders, exchange crypto for cash, manage portfolios or give advice on crypto-assets. They need authorisation, minimum capital, governance standards, segregation of client assets and conflict-of-interest controls.
• Asset-referenced tokens (ARTs). Tokens that aim to hold a stable value by referencing a basket of assets, currencies or commodities.
• E-money tokens (EMTs). Tokens that reference a single official currency, such as the euro or US dollar. Only credit institutions or electronic money institutions (EMIs) may issue them.

Other crypto-assets, such as bitcoin or utility tokens, are covered mainly through white paper disclosure duties for whoever offers them or seeks their admission to trading, plus market abuse rules. The stablecoin titles applied from June 30, 2024, and the rest of the regulation from December 30, 2024.

Passporting and the end of the transitional period

The main commercial benefit of MiCA is the passport. A firm authorised by one national competent authority (NCA) can serve clients in every other member state after a notification process, without applying again in each country.

To avoid a cliff edge, MiCA let firms already operating under national law continue for up to 18 months after December 30, 2024. That outer limit expired on July 1, 2026. Several countries chose shorter windows: the Netherlands, Finland, Latvia, Hungary and Slovenia ended theirs on June 30, 2025, and Sweden on September 30, 2025, according to Elliptic. ESMA also confirmed that firms relying on transitional cover could not passport. Since July 1, 2026, a firm without a MiCA licence or a pending path to one should not be serving EU clients.

The players and the numbers

ESMA publishes an interim MiCA register as weekly CSV files covering white papers, ART issuers, EMT issuers, authorised CASPs and non-compliant entities. Third-party trackers built on that register show steady growth after the deadline.

• Elliptic counted 213 authorised CASP entries across 23 jurisdictions in ESMA’s register as of June 29, 2026.
• Outrun Advisory’s tracker counted 362 authorised CASPs as of September 30, 2026. It classifies about 60% as crypto-native firms and 40% as traditional finance firms, such as banks and asset managers.
• By the same tracker, Germany leads with 96 authorisations, followed by France (36) and the Netherlands (29).
• The European Banking Authority (EBA) reported 39 authorised e-money tokens and no authorised asset-referenced tokens as of September 1, 2026.

Counts differ slightly between trackers because of register timing and how firms with multiple entities are recorded. Readers who need an exact figure should check the current ESMA file directly.

How MiCA treats stablecoins

Stablecoins carry the heaviest requirements. EMT issuers must be licensed banks or EMIs, give holders a right of redemption at par, hold reserves in safe, liquid assets with a share kept as bank deposits, and may not pay interest. Tokens deemed significant face stricter EBA oversight and higher deposit requirements.

The clearest market effect has been on USDT, the largest stablecoin by supply. Tether did not seek MiCA authorisation, citing, according to The Paypers, the requirement for significant EMT issuers to hold 60% of reserves in European bank deposits. Coinbase Europe, Crypto.com, Binance and Kraken all delisted or restricted USDT for EU users between December 2024 and 2025. Circle took the opposite route: its French EMI licence covers both USDC and EURC across the EU, and the two have become the main dollar and euro stablecoins on licensed EU venues.

The squeeze may tighten. In a submission to the Commission’s MiCA review, reported on October 3, 2026, ESMA proposed extending restrictions on non-compliant stablecoins from trading to custody and transfer services. The proposal gives no implementation date or wind-down mechanism.

How the EU approach compares with the US

The US has moved on stablecoins but not yet on market structure. The GENIUS Act, signed on July 18, 2025, created a federal payment stablecoin regime. It takes effect on January 18, 2027, or 120 days after final regulations, whichever comes first. As of mid-2026 several final rules were still pending. The Clarity Act, the proposed market structure bill, failed a Senate vote 49 to 50 in September 2026.

Risks and open questions

• Who supervises. The Commission proposed in December 2025 to move supervision of significant CASPs to ESMA. The ECB backed the plan in April 2026, while Ireland, Luxembourg and Malta expressed reservations, according to Reuters as reported by The Block. Negotiations between member states and Parliament continue.
• Uneven national licensing. Critics argue some NCAs have licensed faster or more lightly than others, which a passport then exports across the bloc. Poland still had no designated CASP supervisor as of the Outrun snapshot.
• Multi-issuance. When the same stablecoin is issued by EU and non-EU entities, as with USDC, reserves are split across jurisdictions. Parliament backed allowing it in July 2026, while the EBA flagged third-country multi-issuer schemes as “significant to very significant” risks in September 2026.
• Gaps in scope. Crypto lending and most decentralized finance sit largely outside MiCA. The EBA has asked the Commission to address lending in its review, with legislative proposals expected in 2027.
• Liquidity fragmentation. Euro and dollar stablecoins available to EU users differ from those dominant globally, which can affect pricing and settlement for cross-border activity.

Sources and further reading

• ESMA: MiCA overview and interim register
• EBA: priorities for the review of MiCA (September 24, 2026)
• Elliptic: what the end of MiCA’s transitional period means (June 29, 2026)
• Outrun Advisory MiCA CASP tracker (figures as of September 30, 2026)
• The Block: ECB backs EU plan to centralize crypto supervision under ESMA
• The Paypers: Tether exits EU market as MiCA rules block USDT