Original Authors: Huang Wenjing, Yan Xuesong

Introduction

Looking back from early 2026, 2025 was a year of reshaping in the crypto world—Bitcoin reached new highs, key projects were launched, and the market steadily rose with rationality. A more profound transformation came from the maturity of global regulation: stablecoins, licensing, and anti-money laundering rules were clearly established in multiple countries, injecting much-needed certainty into the industry.

Among these, the EU MiCA regulation will be fully implemented by the end of 2024, entering a critical landing period in 2025. This unified framework covering 27 countries acts like a beacon, delineating compliance boundaries while illuminating new growth opportunities. As the transitional period officially ended in the fourth quarter of last year, the European market has quietly deepened and restructured—68 new licensed institutions have entered the scene, with traditional VASPs successfully transforming into CASPs, alongside new forces making 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 trends, outline the types and characteristics of new licensed institutions, interpret the differentiated paths of various countries, and reveal the next evolutionary trends in the industry. This will help you penetrate the transformation and gain insight into the true pulse of the European market.

Map of 68 New Licensed Institutions and the New Landscape of the European Market

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

The core of the MiCA regulation is to set a unified entry threshold for crypto asset service providers across Europe. Licensed entities approved by national competent authorities (NCA) can legally operate throughout 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, etc.

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

• Platform-type services: Operating a trading platform usually requires supporting services such as custody, exchange, and order execution to support a complete trading loop.
• Asset management-type services: Portfolio management often needs to be combined with order execution to achieve dynamic rebalancing of managed assets.
• Independent services: Custody, investment advice, transfer, etc., can also exist independently, suitable for institutions focusing on niche areas.

It is important to note that the above possible service combinations are not mandatory and only represent a typical business logic: large comprehensive platforms (like Coinbase, Kraken) usually apply for multiple services because they can support each other to form a closed-loop user experience. However, small or specialized institutions can focus on a single service, such as only providing custody wallets, only offering independent advice, or only operating cross-chain bridges, which is perfectly acceptable.

In practice, various business combinations mainly appear in scenarios where institutions want to provide "one-stop" services; if they only want to operate a very singular business or have budget constraints, they can completely avoid relying on other services, saving both money and effort. This also means that when an institution advertises that it holds a MiCA license, it is best not to assume that it can "do everything."

Understanding this helps us view the strategies and capabilities of newly licensed institutions more objectively and clarify the following common misconceptions:

• Does holding a MiCA license mean complete compliance and no risk?—Not necessarily; the license only represents that it can conduct business within the authorized scope, and does not exclude other operational and market risks.
• Does an institution advertising its MiCA license mean it has all service qualifications?—Not necessarily; its actual business may be limited to custody, exchange, or advice in certain areas.
• Does an institution providing portfolio management necessarily execute trade orders?—Not necessarily; the institution can achieve trade execution by collaborating with third-party licensed service providers.

2. Key Characteristics of Newly Licensed Entities in Q4

In the fourth quarter of 2025, 68 new licensed institutions emerged, directly resulting from the concentration of the MiCA unified regulatory transition period ending in most member countries. Institutions that previously relied on the existing VASP system in various countries faced the final deadline of "license or exit," leading to a wave of concentrated compliance applications and transitions.

This phenomenon is both a natural result of the regulatory transition period and reflects the strategic choices of institutions in adapting to new regulations—whether international giants or local newcomers, all completed their identity transitions before the deadline, reflecting a clear trend of layered evolution and ecological integration in the crypto industry.

• Total Increase: The total number of licensed entities reached 133, with 68 new licensed entities added in the fourth quarter—a significant growth rate, far exceeding the first three quarters.
• Service Concentration: The types of services are mainly custody, transfer, and exchange, with a low proportion of full-service/multi-service licensed entities and a high proportion of narrow authorizations.
• Regional Concentration: About 60% are concentrated in Western Europe (42 entities in Germany, France, the Netherlands, Austria, and Ireland), while Eastern Europe and EEA countries (Liechtenstein) are becoming active.
• Nordic Rise: The Nordic region has made a notable rise: Finland increased from 1 to 5 entities in Q4, and Sweden achieved a presence from none to some.
• Cross-Border Activity: High passport utilization, with most institutions covering more than 10 EU countries.

The Hierarchy of New Licensed Entities: Tension Between Emerging and Traditional Players

Overall, these new institutions can be roughly divided into three categories: Giants, Mid-Tier, and New Players. This classification is based on their scale, market influence, and breadth of services.

1. Giants: Leading Market Unity

Among the licensed institutions in the fourth quarter, the entry of industry giants is particularly noteworthy. These institutions typically tend to apply for more than 5 types of service permissions, building a multi-functional "one-stop" platform covering custody, trading, exchange, etc., to quickly respond to the demands of the EU unified market.

The UK digital bank Revolut obtained a license in Cyprus, providing 6 services including custody, trading platform operation, and fiat exchange, with the potential to bring its over 50 million users into the crypto world. The global exchange KuCoin obtained 5 service licenses in Austria, covering core functions such as 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 typically enjoy international or intercontinental reputations, with a large user base, strong capital, and mature technology. They are expected to quickly expand their operations and capture market share in the EU unified market.
• Internal Integration: Many achieve market entry by establishing subsidiaries, strategically avoiding external risks.

2. Mid-Tier: Steady and Solid Power

Alongside the giants are some mid-tier licensed entities, which typically have a stable and moderately sized user base and mature technology in certain aspects, previously relying on national-level VASP registrations.

For example, Bitonic B.V., established in 2012, is the oldest and largest local Bitcoin broker in the Netherlands, long focused on the domestic market, providing stable and reliable services, and has almost never experienced major security incidents, earning the trust of individual customers. The company obtained its MiCA license on November 21, allowing it to provide custody, exchange, order execution, and transfer services, representing the standard development path of mainstream platforms in the Netherlands—most other new licensed institutions in the Netherlands also possess these types of permissions.

Another typical case is Renta 4 in Spain, a traditional bank in the process of transformation, with a moderate scale and good reputation in the traditional investment field, which has been approved to provide custody and transfer services.

The advantage of these mainstream institutions lies in their deep understanding of the local market, typically choosing a moderate range of service combinations under the premise of controllable compliance costs, avoiding direct competition with large international platforms, and thus becoming a trustworthy choice for ordinary users.

Characteristics:

• Local Deepening Before Expansion: Services in a single country, or gradually moving towards multi-passport.
• Moderate Service Combination: 3-5 types of services.
• Lower Risk: Already have a compliance foundation, with high user loyalty.

3. New Players: Rising Stars

Emerging or localized licensed entities are often smaller in scale, and the emergence of these institutions gives the impression of a "catching up" behavior, as if they are afraid of missing the last train of MiCA.

However, they also fill some local gaps. A typical representative is the 6 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 as a single service. The advantage of these emerging institutions lies in their flexibility and cost advantages.

Characteristics:

• Narrow Service: Focused on local crypto market pain points.
• Potential Risks: Small user base, low business volume or yet to be developed, making them easy targets for future mergers or difficult to fulfill compliance obligations in the long term.

Distribution of New Licensed Entities: Market Drivers Behind the Scenes

The differences in institutional styles across different regions reflect the distinctions in local economies, user habits, and regulatory environments. Western European countries like Germany, France, and the Netherlands dominate the new additions, while Eastern European countries like Slovakia, Slovenia, and Latvia are more retail-oriented in their services.

1. Regional Differences:

Eastern Europe: Clear Retail Orientation, Concentrated Compliance Sprint

In Q4, Eastern European countries added a total of 10 licensed institutions, mainly from Slovakia, Slovenia, and Latvia. These institutions generally focus on retail service combinations, commonly seen in "custody + exchange + transfer" packages, with less involvement in operating trading platforms. For example, institutions like FUMBI in Slovakia hold more than 5 service permissions, while Latvia's BlockBen focuses on the niche market of "gold tokenization."

This phenomenon mainly stems from:

• Concentrated compliance transitions before the end of the transition period;
• The local market being primarily retail-oriented, with low institutional capital participation;
• Relatively low compliance costs compared to Western Europe, attracting many local startups and small to medium-sized institutions;
• Limited regulatory approval resources, with Q4 focused on processing backlog applications.

New Licensed Entities in Western European Countries: Taking France and Germany as Examples

Germany and France are the main representatives of new institutions in Western Europe. Germany added 16 institutions, the vast majority of which are traditional banks, providing only single services of order execution or transfer; France added 5 institutions, among which the crypto department of the "big three" French banks, Société Générale, only applied for custody and transfer services, showing a characteristic of "narrow compliance."

Although Western Europe has mature financial infrastructure and institutional capital, the high compliance costs have led many institutions to choose to streamline their service scope to control initial investments. This also indicates that the activity level of the crypto market is not entirely synchronized with the economic scale of the region.

EEA Countries - Liechtenstein

The emergence of this new name is striking, as the country has registered only two licensed entities, both services revolve around custody, giving a sense of a "small but refined" high-end positioning. The reason lies in its neutral and low-tax environment, which attracts private banks and asset management. Additionally, even though Liechtenstein is not an EU member, MiCA still applies, making the passport value high; the market is niche and high-end, with investors mostly being professional players like family offices.

2. Industry Integration Trend: Invisible Restructuring Rather Than Obvious Mergers and Acquisitions

Although there were no significant merger and acquisition cases in the fourth quarter, the entire industry has actually been quietly integrating. Many giants choose to establish their own EU subsidiaries instead of acquiring others, allowing them to fully control the business while avoiding complex due diligence and approval risks.

Reports indicate that throughout 2025, small institutions have been acquired by mainstream platforms, with the fourth quarter seeing more entities "running on their own"—independently applying before the end of the transition period.

Conclusion

According to incomplete statistics and actual data feedback, the success rate of MiCA applications is not as high as imagined; regulatory agencies still focus on substance: licenses are not the result of piling up application materials, but the natural outcome of a real and reliable business model.

• For investors, the MiCA license is not a one-time "amulet"; the license is just the starting point, not the endpoint. Obtaining a license does not mean the business is necessarily mature; one must look closely to see if there is a specific service, which countries the passport covers, to use it with more confidence.
• For operators, the fact that certain countries or regions have more new entities does not necessarily mean lower regulatory difficulty; it may be a tailored business strategy or expedient measure by existing service providers.

The actual expenses for preparing the MiCA license should not be underestimated; applicants might ask themselves: Do I really need this license? While a proactive attitude towards compliance is commendable, understanding one's positioning and long-term goals may be a wiser move. I hope this article helps you identify opportunities in the European crypto market amidst the transformation.

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