What the 329 Records Actually Measure
Calling every entry an “approval” overstates what the underlying ESMA file records. It combines Article 63 authorisations for crypto-asset service providers with Article 60 notifications from banks, investment firms and other already-regulated financial entities. It also contains several repeated legal entities. The safer description is therefore 329 register records, or roughly 325 named entities, not 329 newly licensed crypto companies.
| Home Supervisor | Register Records |
|---|---|
| Germany, BaFin | 73 |
| France, AMF | 35 |
| Netherlands, AFM | 29 |
| Cyprus, CySEC | 26 |
| Malta, MFSA | 22 |
Those five supervisors account for 185 of the 329 records. Greece, Hungary, Poland and Romania have no home-state entry in the file. That identifies uneven output, not the size of each regulator’s backlog, because ESMA publishes completed authorisations and notifications rather than pending applications. Poland illustrates the practical consequence: its delayed national implementation left local firms without a clear domestic route while firms authorised elsewhere could passport into the country, as FinanceFeeds reported after a second presidential veto.
The Transitional Runway Has Closed
MiCA allowed previously registered providers to continue until their application was granted or refused, or until 1 July 2026 at the latest. That outer deadline has passed. France’s AMF had already instructed unsuccessful applicants to prepare an orderly exit, warning firms months before its four-month review window collided with the deadline.
For clients, a familiar brand is no substitute for checking the regulated legal entity. Some platforms use licensed custody and brokerage partners instead of holding their own CASP authorisation. Nexo’s EEA structure through Tangany and DLT Finance shows how that model can preserve service, but also why customers and brokers must identify which entity safeguards assets, executes orders and covers each product. The same distinction matters when traditional institutions enter the register, including BNY Mellon’s Belgian unit.
MiCA, GENIUS and the UK Still Do Not Line Up
The cross-border problem extends beyond licence counts. MiCA regulates stablecoin issuers and a broad set of crypto services. The US GENIUS Act focuses on payment stablecoins and permits foreign issuers only through comparability, registration and lawful-order requirements. Britain has finalised a wider rulebook, but the FCA says its full perimeter expands on 25 October 2027. A firm moving the same token among the three markets therefore faces different issuer, distribution, custody and timing tests.
Anti-money-laundering coordination remains weaker still. The Financial Action Task Force’s seventh update, published by Japan’s Financial Services Agency, found that 83% of surveyed jurisdictions, 91 of 109, had enacted the crypto Travel Rule. Only 40% of jurisdictions with legislation had taken supervisory or enforcement action. Rubin’s emphasis on regulatory interoperability is therefore material: passporting solves market access inside the EU, but it does not harmonise transfer data or stablecoin treatment across borders.
What Brokers Serving EU Clients Should Check
Brokers should verify the contracting entity in ESMA’s register, match its authorised services to custody, execution, transfer and advice, and confirm any passport notification before onboarding EU clients. They should separately map supported stablecoins, Travel Rule data exchange and third-party dependencies. The commercial prize is substantial: one valid home-state route can unlock the EU single market. The cost of getting the entity or permission wrong is now equally clear, because the transitional shield is gone and a pending application is not permission to operate.
