CASP Licensing in Europe: A Country-by-Country Guide (2026)

On 1 July 2026, the MiCA transition window closes. Crypto-asset service providers operating in the EU under legacy national regimes (VASP registrations, BaFin Kryptoverwahrgeschäft, French PACTE registrations, Italian OAM register, etc.) must hold a MiCA CASP authorisation by then or stop offering services. The headline promise, one licence, 27 markets via passporting, is real, but the country you pick first determines your supervisor for life, your capital expectations, and how quickly you actually get to market. As of 4 May 2026 (data: MiCA SCAN, drawn from the ESMA register and 8 NCAs), the regulated market totals 210 authorised CASPs across 23 countries, plus 20 EMT issuers and zero ART issuers. 86% of CASPs (180) already passport services into other member states. Four country-level facts dominate the picture:

Article 65 of MiCA gives every authorised CASP a right to provide services across the EU on a freedom-of-services or freedom-of-establishment basis. In theory, you choose any one jurisdiction, get authorised, and you're done. In practice, four things break that simplicity:

Counts below come from the MiCA SCAN State of the Market Report dated 4 May 2026, which aggregates the ESMA register with 8 national NCAs. Numbers move week to week; verify against the live ESMA register before acting on a specific application.

Germany is the largest CASP market in the EU by a wide margin: 53 authorised CASPs as of 4 May 2026, more than double second-placed Netherlands. BaFin's path was unusually aggressive: it set a 12-month national transition (closing 30 December 2025) instead of MiCA's full 18 months, and used the legacy Kryptoverwahrgeschäft regime as the on-ramp. Germany is also the top passporting destination, with 151 of the EU's 180 cross-border CASPs choosing Germany as a target market.

France runs a two-regulator model: the AMF (Autorité des Marchés Financiers) leads CASP supervision, while ACPR handles prudential and AML aspects. The country built CASP supervision on top of the existing PSAN (Prestataire de Services sur Actifs Numériques) regime introduced by the 2019 PACTE law.

Italy moved late but firmly. The implementing decree (D.Lgs. 129/2024) designated CONSOB as the lead NCA for CASPs, with Banca d'Italia handling EMT/ART issuers and AML supervision. Italy chose a 12-month national transition closing 30 December 2025.

Spain designated CNMV (Comisión Nacional del Mercado de Valores) as the CASP NCA. Royal Decree-Law 7/2023 set the framework, with subsequent regulations developing technical detail. Spain ended its national transition on 30 December 2025.

The Netherlands designates the AFM (Autoriteit Financiële Markten) as the CASP NCA, with DNB (De Nederlandsche Bank) handling EMT issuers and AML aspects. The Dutch transition runs to the full 1 July 2026 deadline.

Lithuania moved earliest and most aggressively. The Bank of Lithuania (BoL) closed its legacy crypto registration regime in mid-2025 and required all VASPs to either obtain CASP authorisation or wind down. As of 4 May 2026 it has 6 authorised CASPs plus 2 EMT issuers, a smaller cohort than its early-mover reputation suggests, but the active pipeline is large and BoL processing is the fastest in the EU.

Poland is the conspicuous outlier. As of 4 May 2026 the national MiCA enabling legislation is still in draft. This means Poland has not formally designated KNF (Komisja Nadzoru Finansowego) as the CASP competent authority, has not set transitional rules, and has not adopted complementary national provisions. Result: zero authorised CASPs in Poland. Curiously, one Polish EMT issuer has nonetheless been registered, suggesting the EMT pathway through the existing electronic money institution licensing track partially bypasses the missing-CASP-statute problem.

Three smaller hubs that historically attracted CASPs and now must reposition under MiCA. Each has authorised legislation and is processing applications, but the pre-MiCA regulatory arbitrage that drew firms to these jurisdictions has largely evaporated.

Two jurisdictions worth flagging that often get overlooked in CASP planning conversations:

Once authorised in any EU member state, a CASP can extend services to all other member states via passporting (MiCA Articles 64 and 65). Two routes:

Six factors to weigh when choosing your home jurisdiction:

MiCA's promise of a unified EU crypto market is real, but the texture of getting there runs through individual NCAs with their own personalities, processes, and priorities. The 4 May 2026 numbers paint a clearer picture than headline narratives: Germany has built a commanding lead (53 CASPs), the Netherlands has emerged as the surprise second hub (26), and France's strength is weighted toward EMTs (5 issuers) rather than CASPs. Italy is conspicuously absent from the authorisation league with zero CASPs, and Poland sits in the same position because of the still-missing enabling legislation, becoming a competitive liability for the entire Polish crypto sector. For CASPs still planning their authorisation, three observations matter most. First, the 1 July 2026 deadline is not negotiable in most jurisdictions, start now or accept a service gap. Second, your home NCA choice is effectively permanent, switching later means surrendering and re-applying, which costs 9-12 months of revenue. Third, passporting works as designed (180 of the 210 authorised CASPs already use it), so the country you authorise in becomes a strategic choice about who supervises you, not who you sell to.