174 Registered CASPs, however Solely 14 Can Function a Centralized Crypto Trade (CEX)? – Authorized Bitcoin Information

MiCA Decoded is a 12-article weekly collection for Bitcoin.com Information, co-authored by LegalBison’s Co-Founding and Managing Administrators: Aaron Glauberman, Viktor Juskin and Sabir Alijev. LegalBison advises crypto and FinTech firms on MiCA licensing, CASP and VASP functions, and regulatory structuring throughout Europe and past.

If the EU has already issued 174 MiCA licenses, why are there solely 14 precise crypto exchanges on the checklist? To demystify this, we have to decode what the general public registers are actually telling us about how crypto companies are organising in Europe.

That distinction, drawn from the EU and EEA public registers as of March 2026, captures the central query the register raises: which enterprise fashions are touchdown during which jurisdictions and why?

The information solutions that query, and the sample just isn’t what most crypto license holders anticipated.

10 service codes: what MiCA authorizes CASPs to do

The regulation defines 10 classes of crypto-asset providers. The distribution throughout all 174 approved entities breaks down as within the desk beneath (any authorization can cowl a number of of them).

How does a market serving a whole bunch of thousands and thousands of customers have solely 14 approved venues to truly function a stay buying and selling platform?

• Custody and switch providers lead as a result of almost each operator contains them, no matter main enterprise mannequin.
• Switch providers present excessive quantity partly as a result of German conventional monetary establishments added it as a pure extension of current cost infrastructure (credit score establishments, digital cash establishments), because it comes all the way down to a notification course of, the infrastructure work being already current (ICT and DORA compliant). How that authorization applies to totally crypto-native switch fashions remains to be being labored out in apply.

The rarest classes are probably the most telling.

• Solely 14 entities maintain authorization to function a buying and selling platform: a market comparable to an order ebook or matching engine. Instance: Binance’s buying and selling platform, with charts and visible indicators instruments.
• Solely 21 maintain authorization to present funding recommendation: personalised suggestions relating to whether or not a particular crypto-asset is appropriate for the shopper to purchase, promote, or maintain. Instance: eToro points newsletters with skilled opinion on which crypto-asset is value contemplating. The group also can share insights.
• And 30 maintain portfolio administration: managing shopper funding portfolios that embrace crypto-assets. Instance: Wyden Capital focuses purely on creating and managing tailor-made portfolios for buyers.

For founders constructing merchandise in these three service classes, the EU presently has pretty few licensed reference factors to benchmark towards.

The place crypto licenses in Europe are concentrating, and why

• Germany leads the CASP register with 51 authorizations (29%).
• The Netherlands follows with 23 (13%).
• France and Malta observe with 13 (7%) and 12 (7%), respectively.
• Eire and Cyprus observe with 11 (6%) and 10 (6%), respectively.

These headline numbers obscure what’s driving the clustering.

Germany‘s 51 CASPs are dominated by conventional monetary establishments: Commerzbank, DZ BANK, Boerse Stuttgart and regional Volksbanks. The registered entities in Germany are subsequently predominantly retail-banking custodians and broker-dealers, not alternate operators.

Their functions had been predominantly for slender service codes suited to a dealer mannequin serving current fiat account holders. BaFin has processed these kinds of entities for many years. The regulator’s familiarity is appreciable and for banks having already met all the necessities, it’s only a notification course of with the respective competent authority to even be eligible to offer providers beneath MiCA.

Malta and Cyprus inform the alternative story. OKX, Crypto.com, Gemini, Blockchain.com, eToro, and Revolut maintain authorizations in these two jurisdictions.

These platforms utilized for broad service code units protecting buying and selling platform operation, alternate exercise, and order execution. Their regulators in Valletta and Nicosia have processed functions from globally acknowledged alternate manufacturers at scale.

The sensible implication is that, if a crypto alternate license software lands in Germany, it sits in a queue alongside conventional banks making use of for narrower providers, comparable to offering custody and administration of crypto-assets, the execution of orders, and the reception and transmission of orders on behalf of purchasers.

The identical software touchdown in Malta sits alongside established international exchanges.

Regulator familiarity with the applicant’s enterprise mannequin is an actual consider how an software is reviewed, even when the regulation is similar in each locations.

The place did the large names register

For founders selecting a jurisdiction, the register’s most helpful sign just isn’t the nation depend however the firm names behind every flag. Acknowledging which jurisdictions had been chosen by main CEXes, for instance, offers a sign of the place it is sensible for the same challenge to contemplate being registered.

Eire is the place Kraken landed, and the selection displays a pre-existing relationship. Kraken’s group was probably already situated in Eire and already held VASP registrations and an EMI license from the Central Financial institution of Eire earlier than MiCA got here into pressure. This definitely made the Match & Correct analysis of key personnel holding comparable positions on each establishments sooner. Eire was then the pure consolidation level, folding a number of nationwide registrations beneath a single MiCA authorization. It was additionally the primary main international alternate to clear the Central Financial institution of Eire’s CASP authorization course of, which gave the jurisdiction an early alternate reference level.

Luxembourg hosts each Coinbase and Bitstamp. For each, Luxembourg was the jurisdiction the place the regulator had already processed their prior functions. The CSSF‘s observe report with institutional monetary providers explains the clustering. Coinbase explicitly described Luxembourg as its European crypto hub, citing the nation’s strategy to blockchain laws, together with successive blockchain legal guidelines that tailored Luxembourg’s monetary framework for DLT. Bitstamp arrived on the CSSF having already obtained a MiFID license there for working a Multilateral Buying and selling Facility.

Austria is the place Bybit, KuCoin, and the homegrown Bitpanda are based mostly, and the FMA‘s early-mover positioning explains it. Austria accomplished its home MiCA implementing laws forward of most EU member states. Bitpanda, which holds roughly 60% of the Austrian retail crypto market, was already FMA-licensed and had formed the regulator’s familiarity with exchange-type enterprise fashions. When Bybit and KuCoin had been evaluating the place to plant their EU entity, they cited the FMA’s well timed implementation and sensible strategy to the authorization course of. The Austria cluster is then a consequence of Bitpanda having achieved the groundwork first.

Cyprus hosts eToro and Revolut, two platforms whose roots within the retail funding and FinTech house predate their crypto choices. Each had current CySEC relationships earlier than MiCA. Their CASP authorizations prolonged a regulatory relationship already in place relatively than establishing a brand new one.

The Netherlands is the place Bitvavo and MoonPay registered, and the AFM’s early enforcement posture drove the selection. The Netherlands was among the many first EU jurisdictions to grant MiCA authorizations, with its first-wave approvals touchdown in December 2024. Platforms that needed to be among the many earliest licensed within the EU, and that had current Dutch VASP registrations, discovered the AFM pipeline already shifting.

The sample throughout all 5 jurisdictions is identical: exchanges didn’t select regulators abstractly. They went the place the regulator already knew their enterprise mannequin, or the place implementation was furthest forward. That could be a sensible lesson for any founder now evaluating the place to use.

Passporting: staying residence or concentrating on a complete continent

A single MiCA license from any EU member state covers your entire bloc. Passporting requires solely an administrative notification to increase providers to extra member states, with no separate software or second regulator assessment.

When making use of, the applicant is required to state the place it intends to conduct enterprise.

Pan-European platforms have used this absolutely: Kraken, Bitvavo, Bitstamp, Bitpanda, and Commerce Republic have every passported to 29-30 nations (EU + EEA) from a single residence authorization.

Conventional German and Spanish establishments checklist solely their residence nation, confirming that for these entities, MiCA capabilities as home compliance relatively than enlargement infrastructure.

The mechanics matter right here. Underneath passporting, the house regulator stays chargeable for the platform’s ongoing supervision throughout all passported markets. The jurisdiction alternative is subsequently a market-access choice and a regulatory governance choice on the similar time.

Founders constructing for EU retail purchasers don’t want 30 separate functions. One well-chosen authorization, passported throughout the Union, is how Kraken, Bitstamp, and Bitpanda have coated your entire market.

The jurisdictions with no observe report but

Ten jurisdictions inside MiCA’s scope have produced zero public authorization data within the CASP register: Croatia, Estonia, Greece, Hungary, Iceland, Italy, Norway, Poland, Portugal, and Romania.

Poland stands other than the opposite inactive jurisdictions, and its scenario is extra operationally pressing. Together with Lithuania, it was the most well-liked European jurisdiction for crypto licensing earlier than MiCA. As of March 2026, the native implementation of MiCA has nonetheless but to go.

That is changing into a supply of concern for the quite a few VASPs ( crypto firms beneath the previous regime) who’re confronted with the EU-wide deadline of July 1, 2026, with out having the chance to improve their license to a Polish CASP, because the new regime just isn’t stay but.

Romania is the one nation nonetheless listed as “to be introduced” for its NCA (Nationwide Competent Authority) designation.

A lacking NCA designation factors to at least one factor: the home regulatory infrastructure for MiCA oversight just isn’t but in place. Romania has but to decide on (or kind) a nationwide physique chargeable for enforcement and supervision of crypto-asset service suppliers.

The July 1, 2026 deadline applies equally to each jurisdiction of the Union, ready or not. Founders who constructed their European crypto licensing technique round a jurisdiction that has not but activated its regulatory infrastructure are actually dealing with that mismatch, with lower than 4 months to resolve it.

Studying the MiCA register as a crypto license technique sign

The 174 authorizations throughout the EU will not be evenly distributed as a result of enterprise fashions will not be as effectively.

The register displays one thing {that a} studying of the MiCA textual content alone can’t present:

• The place particular varieties of functions land,
• How regulators who course of them examine,
• Which jurisdictions have practical pipelines versus untested ones.

For alternate founders, Malta and Cyprus present probably the most comparable reference pool.

For pure custody and broker-dealer fashions, Germany, Spain and the Netherlands supply probably the most precedent.

For recommendation and portfolio administration merchandise, the takeaway from the information is that the EU has nearly no established reference instances in these classes but.

Constructing these merchandise is feasible beneath the brand new framework, however there isn’t any roadmap from permitted comparable entities. The white paper register research we revealed as of March 19, 2026, confirmed that MiCA’s token regime is used closely by offshore entities as a market-access software, not as a motive to relocate.

The CASP register reveals a distinct sample: operators searching for to serve EU retail purchasers are constructing native presence, selecting jurisdictions based mostly on regulator familiarity with their enterprise mannequin, and passporting from there throughout the total market.

Not all MiCA jurisdictions are equal for each enterprise mannequin. TradFi companies and crypto-native exchanges have sorted themselves by regulator familiarity, not by regulation textual content.

For the 14 approved buying and selling platform operators within the EU, and for the founders who need to be part of that quantity, the register is now probably the most dependable map out there: it was drawn by the businesses that obtained there first.

LegalBison advises crypto and FinTech firms on MiCA licensing, CASP and VASP functions, and regulatory structuring throughout Europe and past.

Extra info at legalbison.com.

This text relies on a research carried out by LegalBison in February 2026, with knowledge up to date as of March twenty third, 2026. The content material is for informational functions solely and doesn’t represent authorized recommendation.