The long-awaited Markets in Crypto-Assets Regulation (MiCA) officially entered into force across the European Union on 30 December 2024, marking a pivotal moment in the evolution of crypto regulation within the single market. For the first time, a harmonized legal framework now governs the issuance of crypto-assets and the licensing of Crypto-Asset Service Providers (CASPs). 

This transformation not only impacts new market entrants but also imposes strict compliance obligations on previously registered virtual asset providers under national laws. But how far along is Europe in licensing CASPs under the MiCA framework? Here’s an in-depth status update as of July 2025.

CASP Licensing in Numbers

Prior to the enforcement of MiCA, crypto regulation across the European Union was fragmented, governed by a patchwork of national frameworks. By the end of 2024, approximately 3,000 crypto-asset service providers (CASPs) had been registered under various domestic regimes — for example, in Czechia under Act No. 253/2008 Coll. on AML/CFT. However, according to estimates from supervisory authorities and industry analyses, only 1,100 to 1,300 of these entities were actively operating across the EU. In the Czech Republic, a significant number of registrations were made between 2021–2023, but a majority of entities either remained dormant or were registered purely for speculative or preparatory purposes. The transition to a unified MiCA framework is expected to significantly reduce the number of CASPs, as national registrations lapse and stricter EU-level licensing requirements take effect.

These national authorizations did not offer passporting rights, limiting providers to operate in one jurisdiction unless separately registered elsewhere. This fragmented structure led to regulatory arbitrage, inconsistent enforcement, and low consumer protection.

After MiCA (2025): Toward a Unified Licensing Framework

Since January 2025, all CASP licenses must conform to the MiCA Title V requirements, which impose robust standards for authorization, organizational governance, capital requirements, and operational integrity.

As of July 2025 more than 40 CASP licenses have been issued across the EU under the MiCA regime. The ESMA public register lists 32 CASPs as officially recognized, including some undergoing supervisory assessment or pending potential rejection.

 

Leading Licensing Jurisdictions

The uptake has been modest but strategically focused.

Key jurisdictions include:

Netherlands – 4 MiCA-compliant CASP licenses

Germany – 1 license (notably issued to a major custody platform)

Luxembourg – 1 license

Many other jurisdictions — including France, Czechia, and Estonia — are actively reviewing applications or transitioning firms from prior VASP statuses to full MiCA-compliant CASP authorizations.

 What This Means for the European Crypto Market

1. Regulatory Consolidation and Legal Certainty

MiCA eliminates jurisdictional inconsistencies by introducing a single licensing passport valid across the EU. This creates a level playing field, reduces compliance fragmentation, and provides regulatory certainty for institutional players and retail consumers alike.

2. Operational Passporting and Market Access

Licensed CASPs can now offer their services across all 27 EU member states without additional local authorizations, provided they comply with ongoing obligations such as:

Real-time risk-based AML/CFT systems,

Asset segregation,

Conflict of interest mitigation,

Consumer disclosure and complaint mechanisms.

3. Increased Supervisory Scrutiny

MiCA introduces a supervisory split: national competent authorities (e.g., ČNB in Czech  Republic) issue licenses, while ESMA and EBA provide regulatory coordination, maintain public registers, and oversee high-risk or systemic CASPs. This dual-tier oversight ensures that systemically important service providers, especially those issuing stablecoins or offering custody, remain under continuous EU-wide surveillance.

 Strategic Implications for CASP Applicants

MiCA imposes substantive documentation, governance, and risk-management requirements, including:

A comprehensive business plan and organizational structure;

Internal control systems, audit mechanisms, and whistleblowing procedures;

Robust AML/CFT policies in line with AMLD6 and FATF recommendations;

Risk classification and mitigation strategies for each service line;

DORA readiness for ICT risk resilience and incident reporting.

Firms that fail to prepare adequately may face delays, rejections, or restrictions on cross-border operations.

 How Artlex Consult Supports CASP Licensing and Beyond

At Artlex Consult, we offer end-to-end legal and regulatory support for crypto-asset service providers aiming to obtain a MiCA-compliant CASP license in Czechia and across the EU.

Our services include:

✔ Strategic & Regulatory Analysis

✔ Full Documentation & Submission

✔ Ongoing Compliance & DORA Integration

✔ Post-licensing supervision support

✔ MLRO outsourcing and regulatory change monitoring.

 Contact us for a tailored CASP licensing roadmap and legal risk assessment:

 Email: info@artlexconsult.com

 Website: www.artlexconsult.com