Germany Claims 79 MiCA Licences as Europe's Crypto Regulatory Map Takes Shape

What just happened

Germany now holds 79 authorised crypto asset service providers under MiCA – the widest national footprint in the European Union. Cointelegraph reported the ESMA registry update that added six cooperative banks in July 2025. Those banks received authorisation to execute client orders in digital assets, but not to provide custody or exchange services – a meaningful distinction that shapes what products German consumers can actually access through them.

The broader European picture: DiarioBitcoin puts France at 35 providers and the Netherlands at 29, with the EU-wide total at 331 entities. ForkLog notes that Germany's regulator BaFin credits the country's advanced banking sector and its pre-existing crypto licensing regime – Germany was operating a national crypto custody licence framework well before MiCA took full effect in December 2024, giving domestic institutions a head start on compliance documentation.

On the stablecoin side, Coinotag covered Revolut's launch of EURR, a 1:1 euro-backed token issued under MiCA's e-money token (EMT) category. EURR operates under a dual regulatory structure: CySEC oversight in Cyprus and CSSF in Luxembourg, which is precisely the cross-border passport mechanism MiCA was designed to enable.

Why it matters

The licence count gap between Germany (79) and France (35) is not just a headline number – it reflects structurally different national approaches. France's AMF has applied its pre-existing PSAN registration system cautiously, with most applicants undergoing extended review. Germany's BaFin, by contrast, converted many holders of the old Section 32 banking licence into MiCA registrations, accelerating the count without requiring firms to start from scratch.

For traders and exchanges, this divergence has real consequences. An exchange licensed only in one EU jurisdiction can passport into all 27 member states under MiCA, but the quality of the licence matters. An authorisation that covers only order execution – like those granted to the six German cooperative banks – does not permit custody. Customers cannot leave assets with those institutions overnight. Firms operating across service categories must hold broader CASP authorisation, and the compliance cost is substantially higher.

The Revolut EURR launch illustrates where MiCA creates competitive advantages. Non-EU stablecoin issuers – Tether being the obvious example – faced delistings on major EU exchanges in early 2025 because USDT is not issued by an EU-licensed entity under the EMT or ART categories. Revolut, holding banking licences across multiple EU jurisdictions, could structure EURR to be immediately compliant. That gives it a distribution advantage over any dollar-pegged token competing for EU retail volume.

For builders deploying DeFi protocols or token issuance infrastructure, the 331-entity figure across the EU signals that the compliance market is real and growing. Third-party custody and execution services are now available in multiple jurisdictions, which reduces the "no compliant counterparty" argument that stalled some institutional DeFi projects in 2023 and 2024.

What changes by Q4 2025

MiCA's full CASP framework has been in force since December 30, 2024. National transition periods for firms that operated under pre-existing national regimes vary: some EU states granted 18-month grandfathering windows, meaning firms that relied on national-level exemptions could continue operating until mid-2026 without full MiCA authorisation. Those windows close progressively, with Germany's pre-MiCA licence conversions largely complete and France's PSAN-to-CASP migration ongoing.

The stablecoin reserve requirements under MiCA are already active. EMT issuers must hold reserves in segregated accounts at EU credit institutions, with at least 30% in deposits and the remainder in highly liquid assets. Issuers above 5 million outstanding tokens face additional supervisory reporting to ESMA. Revolut's EURR launch under CySEC and CSSF oversight means it is subject to these reserve rules from day one.

ESMA is expected to publish technical standards on market abuse reporting and algorithmic trading flags for CASP platforms before the end of 2025. Exchanges operating in Germany, France, and the Netherlands – the three largest CASP registries – will need systems in place to comply once those standards are finalised.

What's still uncertain

The 331-entity EU total masks a significant imbalance: roughly 24% of all licensed providers are in one country. If BaFin's conversion methodology is challenged by ESMA as insufficiently rigorous, some German registrations could face re-examination. No formal challenge is underway, but ESMA has issued guidance indicating it expects national competent authorities to apply substantive review, not just administrative re-labelling of prior licences.

USDT's path back to EU exchanges remains unclear. Tether has publicly stated it is working toward MiCA compliance, but has not confirmed a filing jurisdiction or timeline. Until a Tether entity secures EMT authorisation, USDT remains off-limits for EU-regulated venues offering it to retail clients. Some exchanges have maintained USDT access for professional clients under different regulatory treatment, but that approach carries legal risk as supervisors sharpen their interpretation of the rules.

The interaction between MiCA and DeFi protocols is unresolved. MiCA explicitly excludes fully decentralised services from CASP requirements, but ESMA's working definition of "fully decentralised" is narrow. Protocols with admin keys, upgradeable contracts, or fee-collecting DAO treasuries may fall inside MiCA's scope under interpretations being developed in 2025. No binding ruling has been issued.

Our take

The Germany-France-Netherlands concentration of licences tells us where to look when vetting exchange counterparties in Europe. A CASP authorisation from BaFin or AMF carries more supervisory weight than a registration from a smaller national authority still building its review capacity. When choosing an EU-based exchange, we check whether its MiCA authorisation covers the full service stack – execution, custody, and exchange – not just one category.

For anyone holding stablecoins through EU platforms: EURR and other MiCA-compliant EMTs are now the safe-harbour option for euro exposure. USDC (issued by Circle, which has secured EU EMT status through its French entity) and EURR are the two most accessible compliant options right now. We treat any platform still offering USDT to EU retail clients as carrying unresolved regulatory risk.

Builders planning EU product launches should prioritise Germany and France as primary licensing jurisdictions given their established review processes, then use the MiCA passport to serve other member states. Attempting to secure a first licence in a jurisdiction with limited CASP review experience adds timeline uncertainty without reducing compliance cost.

Watch ESMA's DeFi working group outputs in Q3–Q4 2025. The admin-key question will determine whether a large class of on-chain applications needs to restructure governance before operating in Europe.

FAQ

Which EU country has the most MiCA crypto licences?

Germany leads with 79 authorised crypto asset service providers as of July 2025, ahead of France (35) and the Netherlands (29), out of a total of 331 across the EU.

Is USDT available on EU-regulated crypto exchanges under MiCA?

Not for retail clients on fully licensed EU exchanges. Tether has not yet secured MiCA authorisation as an e-money token issuer, so USDT was delisted from regulated EU retail platforms when MiCA's stablecoin rules came into full force.

What is EURR and how does it comply with MiCA?

EURR is Revolut's euro-backed stablecoin, issued as a MiCA-compliant e-money token under dual regulation by CySEC (Cyprus) and CSSF (Luxembourg), with reserves held in segregated EU bank accounts as required by the framework.