MiCA and the crypto neobank: who's actually licensed in Europe
Europe did something no other major market has managed: it put the entire crypto-financial industry under one rulebook. For crypto neobanks — the hybrids holding your coins and the card programmes spending your stablecoins — MiCA is now the difference between operating in 27 countries and operating in none of them. Here's the practical map.
MiCA in ninety seconds
The Markets in Crypto-Assets Regulation phased in through 2024: stablecoin rules (June 2024), then authorisation for crypto-asset service providers — CASPs — from 30 December 2024, with national grandfathering periods that have been expiring country by country since. Two pieces matter for neobanks:
- CASP authorisation. Custody, trading, exchange and transfer of crypto for clients now require a licence from one national regulator — which then passports across the whole EU/EEA. One approval, 27 markets. ESMA maintains the public register (every crypto profile in our directory links to it).
- E-money tokens (EMTs). Fiat-referencing stablecoins are regulated like e-money: only credit institutions or licensed e-money institutions may issue them, fully reserved, redeemable at par. This is why compliant euro stablecoins (EURe, EURC…) suddenly matter — they're the legally clean settlement asset for European stablecoin cards, and why USDT quietly disappeared from European exchange listings.
Who holds what, in the directory
Among our 357 tracked neobanks, the European crypto stack sorts into four buckets:
| bucket | meaning | tracked examples |
|---|---|---|
| MiCA CASP | Authorised crypto services, EU-passported | Crypto.com, Coinbase, OKX, Bitpanda, Kraken (Krak) |
| Licensed bank + crypto | Banking licence, crypto under it or a CASP add-on | Revolut, Xapo Bank (Gibraltar, EU access via Italy) |
| E-money institution | Fiat side regulated as e-money; crypto partner behind it | Gnosis Pay, Holyheld and most card programmes |
| Self-custodial software | Outside MiCA's core scope — no custody, no CASP needed | MetaMask, Payy, and the whole web3-native wave |
That last row is the strategically interesting one. MiCA regulates intermediaries; fully self-custodial software mostly isn't one. A wallet with a card attached typically needs an e-money arrangement for the card and nothing for the wallet. The result is a two-speed Europe: heavy compliance for custodians, near-zero for self-custody — one more force pushing the industry toward the third wave.
What MiCA actually changed on the ground
- Consolidation. The licence is expensive; the passport is priceless. Big exchanges industrialised their European entities while smaller card programmes quietly exited or got acquired. Expect the hybrid list to keep shortening in Europe even as volume grows.
- Euro stablecoins became real. Pre-MiCA, euro stables were a rounding error. EMT rules gave institutions a compliant instrument, and European card programmes now increasingly settle in regulated EURe/EURC instead of routing everything through dollars.
- The register is public. You can verify any provider's authorisation on ESMA's register — no more taking a landing page's word for it. Our profiles link the register directly; it's part of the verified-links methodology.
- Grandfathering confusion. The transition created a long tail of "operating under national transitional measures" — legal, but weaker than full authorisation. If a provider can't point to a register entry, ask why.
The gaps, honestly
- DeFi and true self-custody are deferred, not resolved. The EU has said follow-up regimes are coming; the AMLR will meanwhile push identification deeper into transfers by 2027. The perimeter will tighten — our reading, flagged as speculation, is that self-custodial interfaces (not protocols) become the next regulatory target.
- Supervision is uneven. One rulebook, 27 supervisors. The regulatory-arbitrage game moved from "which country has rules?" to "which regulator is fastest?" — Malta and Lithuania answered early, drawing scrutiny.
- The US comparison flipped. With the GENIUS Act covering stablecoins but no comprehensive US market-structure law yet in force, Europe is — unusually — the jurisdiction with the clearer rulebook. Whether clarity beats flexibility is the decade's live experiment.