Less than 10% of the crypto companies that were legally serving EU clients as of June now hold the right to do so. MiCA took full effect on July 1, 2026, and the numbers are stark: fewer than 300 out of over 3,000 firms that operated under national VASP registrations have obtained the required Crypto-Asset Service Provider (CASP) authorization. The rest are now in breach of the new regime, facing fines or forced exits.
The licensing cliff
Under MiCA, companies that previously relied on individual member-state VASP registrations had to convert to a CASP license — a single authorization granted by an EU regulator and passported across the bloc. Most didn't make the switch. Ivan Nevzorov, CEO at SBSB Fintech Lawyers, said the gap shows how many firms underestimated the complexity and cost of compliance. “It's not just about money or headcount,” he noted. Even Binance, a platform with deep pockets, struggled to get licensed.
What happens to the unlicensed
Operating without a CASP after July 1 is a direct breach of MiCA. Minimum fines start at €5 million under Article 111, and in France the violation can carry criminal liability. Companies have two paths: wind down in an orderly manner or relocate to a friendlier jurisdiction and rely on reverse solicitation — meaning they can't market into the EU, and clients must come to them on their own.
An orderly wind-down follows ESMA guidelines: stop onboarding new users, halt all marketing into the EU, and restrict activity to settling existing positions. The other option is to transfer clients to an already authorized CASP. But that requires full AML/KYC re-verification for each client — a process that can take months. And many of the newly authorized CASPs are banks that converted existing MiFID or e-money licenses, not crypto specialists. They may not be ready to absorb a large influx of migrating users.
Even the big players felt the squeeze
Binance's well-publicized licensing troubles show that scale alone doesn't guarantee a smooth transition. The exchange eventually secured a CASP in some markets, but the process was drawn out. Nevzorov pointed out that the bottleneck isn't just regulatory — it's also about the shortage of qualified compliance staff and the sheer volume of applications that national authorities had to process.
For the thousands of firms now outside the system, the clock is ticking. Those that haven't started winding down face escalating fines and potential legal action from member-state regulators. The market is consolidating fast, and the survivors are mostly well-capitalized specialists or traditional banks. Nevzorov expects more enforcement actions in the coming months as regulators begin auditing the post-deadline landscape. The next concrete deadline? Firms relying on reverse solicitation must ensure they have zero marketing presence in the EU — one slip could trigger a fine.
