More than a 12 months into the EU’s Markets in Crypto-Assets regime, the register of authorised crypto-asset service suppliers (CASPs) has change into a shorthand for which member states are profitable. On a rely of licences, Germany is comfortably forward.
Konstantins Vasilenko is Co-Founder and CBDO at Paybis, a crypto platform licensed in Latvia. He has greater than 20 years of expertise spanning enterprise IT mission administration, CRM methods, blockchain know-how, digital funds and cryptocurrencies. In this contributed opinion piece, he argues that the licence desk is the unsuitable measure of the place Europe’s crypto infrastructure is being constructed.
Europe has began treating its MiCA authorisation register as a league desk. In the newest September snapshot, Germany leads with 89 authorised crypto-asset service suppliers, forward of France with 35 and the Netherlands with 29. Across the Baltics, Lithuania has 13, Latvia 10 and Estonia three.
Germany is clearly forward if the query is the place permissions have amassed. But the licence desk is the unsuitable measure for the place Europe’s subsequent layer of crypto infrastructure is being constructed.
A MiCA authorisation says little about the infrastructure a agency has behind it. A financial institution including crypto custody and a crypto firm connecting digital belongings to cost and settlement methods can every occupy one line in the similar register.
The desk is beneficial for counting authorisations. It tells us a lot much less about working capability. To see the place crypto companies are gaining the infrastructure to maneuver cash and serve prospects throughout Europe, licence totals usually are not sufficient.
MiCA modified what location means
MiCA has weakened the hyperlink between an organization’s residence jurisdiction and the market it will probably serve. Once authorised in a single member state, a CASP can use the EU’s cross-border notification framework to function elsewhere in Europe. The largest home monetary market doesn’t robotically make the finest base for a cross-border crypto enterprise.
The Baltics know higher than most why licence totals can mislead. Take Estonia, for instance. At the finish of 2019, it had 1,234 licensed virtual-asset companies. By December 2023, after the guidelines tightened, that quantity had fallen to simply 53. Estonia’s expertise reveals how shortly a big licence rely can lose its that means as soon as supervision turns into stricter.
Lithuania’s story could be very completely different. It has 248 fintech firms serving almost 40 million prospects throughout Europe. More than 7,800 individuals work in the sector. Its cost and electronic-money establishments processed €166 billion in funds in 2025. Crypto firms getting into that market are constructing beside a longtime funds trade with skilled groups and methods already transferring regulated cash at scale.
Count what the licence lets a agency construct
The Latvian register reveals that 4 of the nation’s first 10 MiCA-authorised CASPs additionally maintain payment-institution permissions: Paybis, Nexdesk, Nodu Digital and Trek Technologies.
Paybis obtained its MiCA and cost licences collectively in May 2026. Later that month, Nexdesk added a payment-institution licence to the MiCA authorisation it had obtained in December 2025. Trek Technologies obtained each authorisations in May 2026 and Nodu Digital adopted with each licences in July 2026. Four Latvian companies now maintain each MiCA and payment-institution permissions. Three of them, Paybis, Trek and Nodu, obtained each licences at the similar time, all inside lower than two months.
Those paired licences cowl completely different elements of the similar transaction. Customers want to maneuver euros out and in. Businesses want settlement. Platforms want entry to cost methods in addition to permission to deal with digital belongings.
Latvia has tried to make each the regulatory and funds sides of that course of extra predictable. Latvijas Banka expenses €2,500 to assessment a CASP authorisation utility, one in all the lowest utility charges in the EU. It additionally affords candidates limitless free consultations, together with earlier than the firm is legally established. Its pre-licensing course of lets companies take a look at enterprise plans and documentation with supervisors earlier than making a proper submitting.
Latvia’s benefit right here is earlier regulatory suggestions. Firms can discover out what regulators count on and what they should change earlier than submitting formally. Eligible non-bank cost and electronic-money establishments may also entry Latvijas Banka’s EKS cost system instantly for euro funds throughout SEPA.
Volume comes later
The apparent objection is transaction quantity. If the Baltics have gotten an infrastructure centre, why has utilization not already shifted decisively away from bigger markets?
A agency first wants regulatory permission, cost entry, banking connections, merchandise and distribution. Transaction quantity solely begins to indicate the outcome as soon as these items are in place.
There isn’t but sufficient post-MiCA working historical past to say that Latvia or the wider Baltics have overtaken Germany on crypto quantity. But the build-out wanted to compete for that quantity is already seen.
Germany’s massive banks and monetary establishments getting into crypto present that digital belongings are transferring deeper into mainstream finance. In the Baltics, companies are combining crypto authorisation with the cost infrastructure wanted to attach digital belongings to the remainder of the monetary system.
Germany is profitable a distinct contest
Germany will stay a far bigger monetary market than Latvia, Lithuania or Estonia. But MiCA makes home market dimension much less decisive when an organization can set up itself in a single jurisdiction and serve prospects throughout the EU.
If that base additionally provides it entry to the cost system, a small market can carry rather more weight than its dimension suggests. So, sure, the licence desk factors to Germany. However, Europe’s crypto rails are more and more being in-built the Baltics.
AI degree 2 of 5: drafted by our AI editorial assistant from supply materials our editor selected; fact-checked, edited and signed off by Mark Walker, Editorial Director. What the levels mean
