MiCA Approaching its First Anniversary: ​​The New Order Behind 57 Licenses

At the end of December 2025, the EU's regulatory framework for the crypto asset market, MiCA (Markets in Crypto-Assets), will celebrate its first anniversary of full implementation. This year marks not only the implementation of regulations but also the first year that native crypto institutions and traditional financial institutions will formally clash at the same table.

Timeline

The implementation of MiCA was not achieved overnight but was the result of meticulous planning over several years. In the past year, we have witnessed the entire process of CASPs (crypto asset service providers) going from "observation" to "rushing ahead."

Regulatory Focus

MiCA's regulatory focus is no longer abstract principles, but rather sets quantifiable and testable hard thresholds for CASP's actual operation, asset protection, and market transparency.

• Core:Regulatory bodies require CASPs to have a genuine decision-making body within the EU, with at least one director permanently residing in the EU—preventing "mailbox companies."

• Requirements:ESMA/EBA (European Securities and Markets Authority/European Banking Authority) guidelines emphasize that management bodies and qualified shareholders must clearly define their roles, time commitments, and capabilities.

• Core:Hard, testable controls.

  Upon receiving fiat currency from clients, CASP must deposit it with an EU credit institution or central bank before the end of the next business day and must never use client assets for its own accounts. Responsibilities: Require segregation, daily reconciliation, clear custody agreements, and assume liability for losses caused by its own negligence. Core: Strengthen market monitoring and information disclosure. Trading platforms must monitor market abuse and maintain complete order/traceable records. Data Requirements: Must publish pre- and post-trade data (near real-time; free after a 15-minute delay) and keep it available for two years. Order book data must be retained for several years for regulators, and best practices for enforcement must be established.

• Core: For tokens other than ARTs/EMTs, the issuer must be a legal entity and must draft, notify, and publish a crypto-asset white paper before public offering or access.

• Investor Protection: Retail buyers who purchase tokens before trading begins have a 14-day right to withdraw their investment. For tokens without a clearly identified issuer (such as BTC), platforms seeking access are responsible for disclosure and warnings. The biggest advantage of MiCA lies in its "passporting" mechanism. Previously, exchanges wanting to do business in Europe might have needed to apply for licenses in multiple countries, including Germany, France, and Italy. Now, obtaining a CASP license in just one EU member state allows them to operate legally in all 27 member states. This has led to a fierce competition for "license dominance" over the past year. Current Licensing Landscape: Total Number of Licenses Issued: 57 Popular Registration Locations: Germany: A Compliance Fortress for Banks and Custodians Germany boasts the largest number of licenses and the highest value, making it a center for the integration of traditional finance and crypto. If institutions seek a "bank-level compliance image" and wish to establish connections with deep capital markets, Germany is the preferred destination for such "regular" entities. Netherlands: The Artery of Payment and Fiat Currency Channels The second largest location after Germany, exhibiting strong native crypto and payment integration attributes. The regulatory environment here is extremely well-suited to the brokerage model.