Less than three weeks before the EU's Markets in Crypto-Assets (MiCA) regime fully kicks in, only about 210 firms have secured a licence — roughly 7% to 8% of the 2,747 virtual asset service provider (VASP) registrations that existed across the bloc before the rules took effect. That gap has regulators and law firms bracing for a scramble, especially among smaller startups that face the same compliance burden as giants like Coinbase or Binance.
The licensing gap
Patrick Hansen, director of EU strategy at Circle, tracked 39 Crypto Asset Service Provider (CASP) licences and 14 stablecoin issuer approvals among the first 54 MiCA authorisations as of early 2026. The slow uptake echoes a broader trend: Estonia's licensed VASPs collapsed from 641 in June 2021 to just 40 by February 2025. In France, only 30% of roughly 90 unlicensed firms had even applied for MiCA authorisation as of January, with 40% saying they didn't intend to apply at all.
The burden on small firms
MiCA rules apply uniformly to all firms, regardless of size. That flat structure places a disproportionate load on smaller startups — the ones that used to operate under lighter national regimes. After July 1, unlicensed entities have a few options: obtain a licence, stop operating, wind down, transfer clients to a licence-holder, or merge with one. The French AMF has warned that failure to comply could lead to criminal prosecution.
Consolidation ahead
Law firms are already betting on a wave of M&A through the second half of 2026. Ignacio Santos, CEO of Fazil Crypto, said his firm has seen heavy inbound interest from European and non-European firms after it obtained a Spanish CASP licence. That licensing appetite suggests the few who already hold a MiCA stamp may become acquisition targets — or gatekeepers for smaller players looking to survive.
The July 1 deadline is fixed. Unlicensed firms still in operation after that date face potential enforcement action. The unanswered question: how many of the roughly 2,500 previously registered VASPs will simply vanish, and how many will find a partner before the regulators come knocking?
