ESMA Interim MiCA Register. Full Analysis: CASPs · EMT Issuers · White Papers · Non-Compliant Entities

ESMA's Interim MiCA Register — published weekly and last updated on 23 March 2026 — is the authoritative EU-wide public record of authorised crypto-asset service providers, e-money token issuers, asset-referenced token issuers, published crypto-asset white papers, and entities flagged as non-compliant. We analysed all five CSV files directly to produce this complete cross-register breakdown.

The register currently shows zero authorised ART issuers (the ART file contains only a header row). This article therefore covers the four active registers: CASPs (Title V), EMT issuers (Title IV), White Papers for other crypto-assets (Title II), and Non-Compliant Entities.

1. Authorised Crypto-Asset Service Providers (CASPs)

Under Title V of MiCA, crypto-asset service providers must obtain authorisation from their national competent authority (NCA) before providing any of the regulated services listed in Article 60. The authorisation grants EU-wide passporting rights. As of 23 March 2026, the ESMA register records 171 unique authorised CASPs across 20 jurisdictions.

1.1 Authorisations by Country

Country	Key Authorised Names	Count	Notable Observations
🇩🇪 Germany	Commerzbank, N26, DekaBank, flatexDEGIRO, Baader Bank, Trade Republic, Scalable Capital, Bullish, BitGo, Berenberg, DZ BANK, MLP Banking, Bitpanda AM, EUWAX, Tradias, IG Europe, Tangany, Hauck Aufhäuser + 32 more	50	Dominant due to incumbent banks integrating crypto alongside existing financial licences. Almost unique in EU.
🇳🇱 Netherlands	Bitvavo, MoonPay Europe, BTC Direct, Bitonic, One Trading Exchange, BLOX, Amdax, Blockrise, Vivid Money, Finst, Coinmerce, Bitmymoney, zerohash europe, Hidden Road, Acheron + 8 more	23	All operating under full MiCA auth — national transitional period expired July 2025.
🇫🇷 France	Société Générale – Forge, CACEIS Bank, CoinShares AM, Banque Delubac, Bitstack, Deblock, Goin, Finctek, Relai, Cometh, Fipto, Meatal Gear	12	Strong traditional bank presence. Circle (USDC issuer) licensed both as CASP and EMT issuer.
🇲🇹 Malta	OKX, Crypto.com, Gemini, Blockchain.com, Gate, Bitpanda, Socios.com, ZBX, Altarius AM, Payhound, Damex, BVNK	12	Global exchange hub. ESMA peer review (July 2025) flagged MFSA authorisation rigour for improvement.
🇮🇪 Ireland	Kraken (×2 entities), Interactive Brokers IE, StoneX, Skrill/NETELLER, Ramp Network, CoinJar, Aave/Push, Legend Trading, Confirmo, Webot	11	Gateway for US financial firms entering EU. Two separate Kraken legal entities (different LEIs).
🇨🇾 Cyprus	Revolut, eToro, Capital.com, Trading 212, XTB, Tradu, Teroxx Digital, Collect & Exchange, Pelican Exchange, Noemon Finance	10	Fintech/retail trading hub. Revolut's CySEC MiCA licence covers 30 EEA countries.
🇦🇹 Austria	Bybit, Bitpanda, AMINA EU, 21bitcoin, KuCoin EU, DADAT, Coinfinity	7	Transitional period ended Dec 2025; all 7 hold full MiCA authorisation.
🇨🇿 Czechia	Invity Finance, COINMATE, ILAVO GROUP, MP Developers, Pluso, MipSoftware	6	Domestic crypto-native platforms; Czech CNB active authoriser.
🇸🇰 Slovakia	FUMBI, BITCOINMAT, Firefish, Cryptovoucher, Madison Six/crypto4me, Okazio	6	NBS active; small market but strong showing for a country of its size.
🇱🇺 Luxembourg	Clearstream, Coinbase, Bitstamp, Zodia	4	Institutional infrastructure names. US exchanges chose Luxembourg for EU base.
🇱🇹 Lithuania	Robinhood, Coingate, Simplex, Myriad Capital	4	Robinhood's EU licence is notable — the US retail brokerage chose Lithuania as its EU gateway.
🇫🇮 Finland	Coinmotion, Tesseract, Bittimaatti, NorthCrypto, Kvarn X	5	All domestic Finnish platforms.
🇱🇮 Liechtenstein	Bank Frick AG, LGT Bank AG, ZEUS Anstalt, Wyden Capital, Celsion Bank	5	All private banks or asset managers. Strong showing for an EEA micro-state.
🇪🇸 Spain	5 CASPs authorised under CNMV	5	Extended transitional period to 30 June 2026 — more authorisations expected.
🇩🇰 Denmark	Penning, Lunar Block, GCEX	3	Small but active market.
🇸🇮 Slovenia	Ilirika, Incrementum, Orcabay	3	Transitional period expired July 2025.
🇱🇻 Latvia	BlockBen, Nexdesk	2	Transitional period expired July 2025.
🇧🇪 Belgium / 🇧🇬 Bulgaria / 🇸🇪 Sweden	KBC (BE) · Alaric Securities (BG) · Safello AB (SE)	1 each	Sweden's transitional period expired Sep 2025.

Note: The ESMA register counts one record per CASP per authorisation notification. Where a company appears with multiple service codes or passporting destinations, it is counted as one CASP based on unique LEI. Withdrawn authorisations (those with an ac_authorisationEndDate) are excluded from the counts above.

2. E-Money Token (EMT) Issuers — Title IV

E-money tokens are crypto-assets that reference the value of an official currency and qualify as electronic money under the EU E-Money Directive. Issuers must hold an electronic money institution (EMI) or credit institution licence and be authorised under Title IV of MiCA. The register records 38 white paper entries from 18 unique authorised EMT issuers across 11 countries. No ART issuers are currently authorised (the ART register contains only a header row).

2.1 EMT Issuers by Country

Country	Issuers	Names	Notes
🇫🇷 France	5	Circle Internet Financial Europe (USDC) · Société Générale – Forge · SALVUS · Oddo BHF · OuiTrust	Circle holds 2 white papers (USD Coin, EURC). SocGen Forge holds 2 (EURCV, USDCV). France leads EU stablecoin authorisations.
🇳🇱 Netherlands	2	Fiat Republic (3 WPs) · Quantoz Payments (5 WPs)	Quantoz most prolific EMT issuer in NL with 5 separate white papers.
🇱🇹 Lithuania	2	Ambr Payments (2 WPs) · BLUE EMI LT (2 WPs)	Both hold 2 white papers each.
🇲🇹 Malta	2	StablR Ltd (2 WPs) · Stable Mint (2 WPs)	Malta active in both CASP and EMT segments.
🇩🇪 Germany	1	AllUnity GmbH (4 WPs)	AllUnity is the most prolific single EMT issuer by white paper count.
🇨🇿 Czechia	1	Stable Labs (3 WPs, limited network exception)	Operates under Art. 48(4/5) limited network exemption; not for general public.
🇫🇮 Finland	1	Paxos EU (3 WPs)	US-based Paxos chose Finland as its EU EMT authorisation jurisdiction.
🇱🇺 Luxembourg · 🇩🇰 Denmark · 🇮🇸 Iceland · 🇵🇱 Poland	1 each	Banking Circle (LU) · Eurodollar (DK) · Monerium (IS) · StaBillon (PL)	Monerium (Iceland) is notable as the only EEA non-EU EMT issuer.

ART REGISTER (Title III) — ZERO AUTHORISATIONS

As of 23 March 2026, ESMA's ART issuers CSV (ARTZZ.csv) contains only a header row with no data entries. No asset-referenced token issuer has yet been formally authorised under MiCA Title III. This reflects the significantly higher regulatory burden for ARTs compared to EMTs, including mandatory reserve requirements, recovery plans, and in the case of 'significant' ARTs, direct EBA supervision.

3. Crypto-Asset White Papers — Title II

Issuers of crypto-assets other than ARTs and EMTs (utility tokens, governance tokens, payment tokens, etc.) must publish a white paper and notify it to their national competent authority, which then provides the data to ESMA for inclusion in the register. As of 23 March 2026, the register contains 809 white paper entries covering a wide range of projects.

Unlike the CASP and EMT registers, white papers are not 'approved' — the NCA review is a notification process, and the register explicitly states that white papers have not been reviewed or approved by any competent authority. The issuer remains solely responsible for the content.

3.1 White Paper Notifications by Country

Country	WPs	Notable Issuers / Projects	Observations
🇮🇪 Ireland	298	VeChain, IoTeX, Walrus Foundation, Velodrome, Celo Foundation, Venice.ai, Zora Labs, Bera Chain Foundation, Bubblemaps, Risk Labs + many global crypto projects	Ireland's CBI is the most-used white paper jurisdiction by far. Almost all 298 are non-Irish global projects using Ireland as their EU notification route. All 298 filed with the Central Bank of Ireland.
🇲🇹 Malta	145	Socios Technology AG (26 WPs), Socios Services Ltd (15 WPs), Socios Technologies AG (9 WPs), QuantiID Systems (2 WPs), Virtuals Protocol (2 WPs)	Socios group alone accounts for 50+ white papers. Malta is the chosen jurisdiction for Socios's entire portfolio of fan token white papers.
🇩🇪 Germany	107	Crypto Risk Metrics GmbH (89 WPs), tokenforge GmbH (3 WPs), XGR.Network (2 WPs) + others	Crypto Risk Metrics GmbH dominates German WP filings with 89 notifications — suggesting a white paper notification service model.
🇱🇮 Liechtenstein	71	LCX AG (4 WPs), Tiamonds AG, SwissFortress AG, Soul Protocol, xMoney Labs, Regen AG, MatterFi + many Web3 projects	Liechtenstein's TVTG framework attracted crypto-native projects pre-MiCA; many now migrating to MiCA white paper regime.
🇳🇱 Netherlands	54	12 unique issuers including various DeFi and infrastructure projects	Diverse range; Netherlands WP filings align with its broad CASP ecosystem.
🇱🇺 Luxembourg	35	Bitstamp Europe S.A. (20 WPs) + 12 other issuers	Bitstamp accounts for 20 of Luxembourg's 35 WPs — likely covering the full range of tokens listed on the exchange.
🇫🇷 France	20	ABC Labs, Obol Association, NAEST, Crypto Blockchain Industries, CheerBitcoin + 9 more	Mix of DeFi infrastructure, tokenised assets, and crypto-native projects.
🇦🇹 Austria / 🇱🇻 Latvia / 🇪🇸 Spain / 🇮🇹 Italy / 🇱🇹 Lithuania / 🇨🇾 Cyprus / 🇫🇮 Finland / 🇨🇿 Czechia / 🇪🇪 Estonia / 🇩🇰 Denmark	2–9 each	Various smaller projects filed with national NCAs	Estonia and Finland show early adopter activity. Italy (6 WPs) is notable given its heavy non-compliant enforcement activity.

WHITE PAPER TOTAL: 809 ENTRIES

The 809 white paper entries reflect a broad mix: large crypto platforms filing for their entire token listing catalogues (e.g. Socios, Bitstamp, Crypto Risk Metrics), global Web3 projects using Ireland or Liechtenstein as their EU notification route, and domestic issuers in smaller markets. The register is expected to grow significantly as more platforms migrate legacy token listings to the MiCA white paper regime ahead of July 2026.

4. Non-Compliant Entities

Articles 109–110 of MiCA empower ESMA to maintain a register of entities providing crypto-asset services without authorisation. National competent authorities report these entities to ESMA, which publishes them centrally. As of 23 March 2026, the register lists 101 non-compliant entities. Entries remain in the register permanently — they are not removed when a firm ceases operations.

4.1 Non-Compliant Entities by Country

Country / Authority	Count	Notes
🇮🇹 Italy (CONSOB)	99	CONSOB flagged 99 entities between April 2025 and July 2025 — by far the most active enforcer in the register. Entities include offshore exchanges, investment fraud platforms, and unregistered providers with names like Dobibo, Atomic Wallet, MEXC (separate NL entry), various coded names (DFG789, RYR888, etc.), and platforms previously known to target retail Italian investors. CONSOB has an established track record of website-blocking orders against unlicensed crypto firms.
🇳🇱 Netherlands (AFM)	1	MEXC flagged by the AFM. MEXC is a large global crypto exchange that has historically operated in the EU without local authorisation.
🇸🇰 Slovakia (NBS)	1	LWEX flagged by the National Bank of Slovakia.

KEY OBSERVATION: ENFORCEMENT CONCENTRATION

The extreme concentration of non-compliant entries in Italy (99 of 101) reflects CONSOB's proactive enforcement posture rather than Italy being uniquely problematic. Most EU regulators have not yet reported entities to the ESMA register. As national transitional periods expire through 2025–2026, expect this register to grow substantially across all jurisdictions.

5. Grandfathering Deadlines by Member State

The 171 authorised CASPs represent only those that have completed the full MiCA authorisation process. Many firms continue to operate under national transitional provisions (Article 143(3) MiCA) while their applications are processed. These 'grandfathering' periods vary by Member State and are listed below. All periods expire by 1 July 2026 at the latest — after which no firm may provide crypto-asset services in the EU without a full MiCA authorisation.

Member State(s)	Deadline	Status
🇳🇱 NL · 🇱🇻 LV · 🇭🇺 HU · 🇸🇮 SI · 🇫🇮 FI	~July 2025	EXPIRED — full MiCA authorisation required
🇸🇪 Sweden	30 Sep 2025	EXPIRED
🇦🇹 Austria	31 Dec 2025	EXPIRED
🇱🇹 Lithuania	~Dec 2025	EXPIRED (extended from 5 months to 12 months)
🇮🇹 Italy · 🇧🇬 Bulgaria	~June 2026	18 months (extended from 12 months)
🇪🇸 Spain	30 June 2026	18 months (extended from 12 months in Dec 2025)
🇫🇷 France · 🇲🇹 Malta · 🇱🇺 Luxembourg · 🇪🇪 Estonia + others	1 July 2026	Maximum 18-month transitional period

Critical: after 1 July 2026, operating without a MiCA authorisation constitutes a regulatory violation exposable to administrative fines of up to €5 million or 3% of annual turnover, suspension or withdrawal of authorisation, public infringement notices, and management bans. ESMA has explicitly stated that last-minute applications will face heightened scrutiny.

6. How Licentium Can Help

We advise clients on MiCA regulatory compliance, authorisation strategy, and ongoing supervisory engagement across all EU and EEA jurisdictions. Our services include:

•       MiCA CASP authorisation applications and NCA engagement (BaFin, AFM, CBI, CySEC, MFSA, CSSF and others)

•       Jurisdiction analysis and domicile selection for EU market entry

•       Grandfathering deadline mapping and cross-border compliance gap analysis

•       Crypto-asset white paper drafting and iXBRL format compliance (mandatory since 23 December 2025)

•       EMT and ART issuer authorisation under Titles III and IV MiCA

•       ESMA Interim Register monitoring and non-compliant entity risk assessment

•       Orderly wind-down planning for CASPs in expired transitional jurisdictions

The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. Data sourced directly from ESMA Interim MiCA Register CSV files (last updated 23 March 2026). Some parts of the text may be automatically generated. The author makes no guarantees or warranties about the accuracy or completeness of the information.