MiCA Implementation Countdown: Overview of the 2025 European Licensed Entities Trend

Original Authors: Huang Wenjing, Yan Xuesong

Introduction

Looking back at the beginning of 2026, 2025 was a year of reshaping the crypto world—Bitcoin reached new highs, key projects were launched one after another, and the market steadily moved upward in a rational manner. More profound changes stem from the maturing of global regulation: stablecoins, licensing, and anti-money laundering rules were clearly implemented in multiple countries, injecting long-awaited certainty into the industry.

Among them, the EU MiCA regulation was fully implemented at the end of 2024, entering a critical phase of enforcement in 2025. This unified framework covering 27 countries is like a beacon, delineating compliance boundaries while illuminating new growth opportunities. When the transition periods in many countries officially ended in Q4 last year, the European market had become calm and restructured—68 new licensed institutions entered the scene, traditional VASPs successfully transformed into CASPs, and new forces made a strong debut.

36-Month MiCA Timeline for Licensed Entities Providing Crypto Asset Services

(Source: Latest guidance from ESMA official website)

This article will start from the latest regulatory developments, review the types and characteristics of new licensed institutions, interpret the differentiated paths of various countries, and reveal the next evolution trend of the industry. Help you see through the transformation and grasp the true pulse of the European market.

68 New Licensed Institutions Map and the New European Market Landscape

1. The Logic of Service Licensing: Licenses ≠ All-Powerful

The core of MiCA regulation is to set a unified access threshold for crypto asset service providers across Europe. Entities approved through review by national competent authorities (NCA) can operate legally across the EU via the “passport” mechanism (EU Passport). According to MiCA, licensed institutions can provide 10 types of services, including custody, operating trading platforms, exchange, order execution, investment advice, and more.

However, the scope of license authorization varies greatly depending on the service combination chosen during application. Common business logic includes:

• Platform-type services: Operating trading platforms usually require supporting custody, exchange, order execution, etc., to support a complete trading cycle.
• Asset management services: Portfolio management often needs to be combined with order execution to enable dynamic rebalancing of assets under management.
• Independent services: Custody, investment advice, transfers, etc., can also exist independently, suitable for institutions focusing on niche areas.

It’s important to note that the above service combinations are not mandatory; they merely represent typical business logic: large integrated platforms (like Coinbase, Kraken) usually apply for multiple services because they can form a closed-loop user experience through mutual support. Smaller or specialized institutions can choose to offer only a single service, such as custody wallets, independent advice, or cross-chain bridges—this is perfectly fine.

In practice, various business combinations mainly appear in scenarios where providers aim to offer “one-stop” services; if they only want to operate a very simple business or have limited budgets, they can completely avoid relying on other services, saving money and effort. This also means that when an institution claims to hold a MiCA license, it’s best not to assume it can do “everything” automatically.

Understanding this helps us objectively view the strategies and capabilities of newly licensed entities, and clarify common misconceptions:

• Does holding a MiCA license mean full compliance and risk-free operation?—Not necessarily. The license only indicates that the entity can operate within the scope of approval; operational and market risks still exist.
• Does claiming to have a MiCA license mean the institution has all service qualifications?—Not always. Its actual business may be limited to custody, exchange, or advice.
• Can an institution providing portfolio management also execute trades?—Not necessarily. It may cooperate with third-party licensed service providers to carry out trade execution.

2. Key Features of New Licensed Entities in Q4

In Q4 2025, 68 new licensed institutions appeared, directly resulting from the end of the transitional period for MiCA’s unified regulation in most member states. Previously, institutions relying on their national VASP systems faced a final deadline of “licensing or exit”, leading to a wave of compliance applications and conversions.

This phenomenon is a natural outcome of regulatory transition and reflects the strategic choices of institutions adapting to new rules—whether international giants or local startups, all completed their identity transformation before the deadline, highlighting a clear trend of layered evolution and ecosystem integration in the crypto industry.

• Total increase: The total number of licensed entities reached 133, with 68 new licenses in Q4—a significant growth rate, far exceeding the first three quarters.
• Service concentration: The main services are custody, transfers, and exchanges; licensees with full or multi-service licenses are a minority, with narrow scope licenses dominating.
• Regional concentration: About 60% are concentrated in Western Europe (Germany, France, Netherlands, Austria, Ireland with 42 entities combined), while Eastern Europe and EEA countries (Liechtenstein) are becoming active.
• Nordic emergence: The Nordic region is “rising”: Finland increased from 1 to 5 entities in Q4, Sweden went from zero to multiple.
• Cross-border activity: High passport utilization, with most institutions covering more than 10 EU countries.

Hierarchy of Newly Licensed Entities: Emerging vs. Traditional

Overall, these new entities can be roughly divided into three categories: giants, mid-tier, and new players. This classification is based on their scale, market influence, and service breadth.

1. Giants: Leading the Market Unification

In Q4, the entry of industry giants was particularly notable. These institutions tend to apply for more than 5 service types, building comprehensive “one-stop” platforms covering custody, trading, exchange, and other functions, quickly responding to the EU’s unified market demands.

UK digital bank Revolut obtained a license in Cyprus, offering 6 services including custody, trading platform operation, and fiat currency exchange, potentially bringing its over 50 million users into the crypto world. Global exchange KuCoin obtained 5 service licenses in Austria, covering custody, exchange, and underwriting; meanwhile, Blockchain.com (Malta) and crypto bank AMINA EU (Austria) also entered the market as comprehensive service providers.

Characteristics:

• Economies of scale: These licensed entities usually enjoy international or intercontinental reputation, with large user bases, strong funding, and mature technology. They are expected to expand quickly and capture market share within the EU.
• Internal integration: Many establish subsidiaries to enter the market, strategically avoiding external risks.

2. Mid-tier: Steady and Reliable

Alongside giants are some mid-tier licensed entities, which typically have moderate and stable user bases and mature technology in certain areas, previously relying on national VASP registration.

For example, Bitonic B.V., founded in 2012, is the Netherlands’ oldest and largest local Bitcoin broker, focusing on the domestic market with stable, reliable service and almost no major security incidents, trusted by retail clients. It obtained a MiCA license on November 21, allowing custody, exchange, order execution, and transfer services, representing the standard development path for mainstream Dutch platforms—most new Dutch licensees now have these permissions.

Another example is Spain’s Renta 4, an established bank in transition, with moderate size and good reputation in traditional investment, approved to provide custody and transfer services.

The advantage of these mainstream institutions lies in their deep understanding of the local market, often choosing a moderate service scope to control compliance costs, avoiding direct competition with large international platforms, thus becoming trusted choices for ordinary users.

Characteristics:

• Deep local focus, expanding outward: Single-country services or gradually moving toward multiple passports.
• Moderate service scope: 3-5 service types.
• Lower risk: Existing compliance foundation, high user loyalty.

3. New Players: Rising Stars

Emerging or localized licensed entities are often smaller in scale, appearing as “catch-up” behaviors to avoid missing the MiCA deadline.

However, they also fill some local gaps. Typical representatives include six local banks in Germany (Volksbank Mittlerer Schwarzwald eG, Hannoversche Volksbank eG, VR TeilhaberBank Metropolregion Nürnberg eG, etc.), all approved in December but only able to provide order execution services. These new institutions are characterized by flexibility and cost advantages.

Characteristics:

• Narrow scope services: Focused on local crypto market pain points.
• Potential risks: Small user base, limited or no business volume, potentially targets for future M&A or difficulty maintaining long-term compliance.

Distribution of New Licensed Entities: Market Drivers Behind

The regional differences in institutions’ styles reflect local economies, user habits, and regulatory environments. Western European countries like Germany, France, and the Netherlands lead in new licenses, while Eastern European countries like Slovakia, Slovenia, and Latvia are more retail-oriented.

1. Regional differences:

Eastern Europe: Retail-focused, compliance surge

In Q4, Eastern European countries added 10 new licensed entities, mainly in Slovakia, Slovenia, and Latvia. These institutions generally focus on retail service combinations, such as “custody + exchange + transfer,” with few involved in operating trading platforms. For example, Slovakia’s FUMBI and Latvia’s BlockBen hold over 5 service permissions, with BlockBen specializing in “gold tokenization.”

This phenomenon mainly results from:

• Concentrated compliance conversions before the transition period ended;
• Local markets dominated by retail, with low institutional participation;
• Lower compliance costs compared to Western Europe, attracting many local startups and small institutions;
• Limited regulatory resources, leading to a backlog of applications processed in Q4.

Western European countries’ new licenses: France, Germany as examples

Germany added 16 institutions, mostly traditional banks offering only order execution or transfer services; France added 5, with the “Big Three” banks’ crypto divisions applying mainly for custody and transfer, showing a “narrow scope compliance” approach.

Despite mature financial infrastructure and institutional capital, high compliance costs lead many to choose streamlined service scopes to control initial investments. This indicates that crypto activity does not fully align with regional economic size.

EEA countries—Liechtenstein

The appearance of Liechtenstein is notable, with only two licensed entities, both focusing on custody, giving a “small but high-end” impression. Its neutral, low-tax environment attracts private banks and asset managers. Although Liechtenstein is not an EU member, MiCA applies, making passporting valuable; the market is niche and high-end, with investors mainly family offices and professional players.

2. Industry consolidation trend: Hidden restructuring rather than overt M&A

Although no obvious M&A cases appeared in Q4, the industry is quietly consolidating. Many giants choose to establish their own EU subsidiaries rather than acquire others, allowing full control and avoiding complex due diligence and approval risks.

Data shows that in 2025, some small institutions were acquired by mainstream platforms, but in Q4, most are “doing it themselves”—applying independently before the transition ends.

Conclusion

Based on incomplete statistics and actual data feedback, the success rate of MiCA applications is not as high as expected. Regulatory review still emphasizes substance: a license is not just a pile of application materials but a natural result of a genuine, reliable business model.

• For investors, a MiCA license is not a foolproof “shield”—it’s just a starting point, not the end. Holding a license does not mean the business is mature; it’s essential to verify whether specific services are offered, which countries are covered, to use with confidence.
• For operators, the surge of new entities in some countries or regions does not necessarily mean lower regulation difficulty; it may be a tailored business strategy or a stopgap measure.

The actual costs of obtaining a MiCA license are not negligible. Applicants should ask themselves: do I really need this license? While embracing compliance is commendable, clarifying your positioning and long-term goals is likely a wiser choice. We hope this article helps you identify opportunities in the European crypto market amid ongoing transformation.