Europe's crypto transition period ended on 1 July, and the first full read of the new MiCA register shows a licensed market that is far smaller than the old one — and heavily weighted toward custody rather than trading venues. The ESMA register, updated on 12 August, lists 329 authorization rows covering 324 identifiable legal entities. Of those, just 21 are allowed to operate a trading venue, about 6.5% of the licensed market.
The shape of the register
Custody is the biggest licensed category, with 218 entities. Transfer services follow at 203, exchange crypto for fiat at 181, and order execution at 168. The numbers overlap — one firm can hold several authorizations — but the tilt is clear. Trading venues are the exception, not the rule. That matters because the venue license is the one that lets a firm actually match buyers and sellers.
142 entities, about 44% of the register, have notified at least 27 target markets, meaning they intend to passport services across the bloc. The rest are staying closer to home.
The old guard didn't convert
The transition was never going to be a straight swap. Most old VASP registrations did not become MiCA licenses. The conversion rate works out to roughly 25% to 10% — 324 licensed entities against the 1,200 to 2,700 VASPs that operated before MiCA. James Harris, CEO of Tesseract Group, puts it bluntly: CASP authorization is 10 to 15 times harder than operating as a VASP. The numbers back him up.
A market that once had thousands of registered players now has a few hundred, and the ones that stayed had to rebuild their compliance from the ground up.
What a license costs
The price of staying in the game is steep. Initial legal and advisory work runs €40,000 to €150,000. Compliance build-out adds €20,000 to €80,000. DORA technology costs another €30,000 to €80,000. Then the recurring annual costs land at €150,000 to €500,000. For a mid-size firm, that's a serious line item before a single trade. It also explains why so many smaller VASPs walked away rather than apply.
Stablecoins and the split
Circle supplies about 92% of the tracked MiCA-compliant stablecoin market, which gives it an effective lock on the regulated end of that business. Meanwhile, national regulators have applied the same EU rulebook in sharply different ways. The register is one thing; how a firm actually gets supervised still depends on where it's based. That divergence is the quiet problem under the headline numbers.
The next thing to watch is how the 27 target-market notifications actually play out in practice — and whether the divergence between national regulators narrows or hardens as the first full year of MiCA supervision gets underway.
