Roughly one in six firms on the MiCA register is a bank. They got there through a different door than everyone else, they choose noticeably different services, and they are wildly unevenly distributed: nearly half of Germany's register is banks, against 6% of France's and 3% of the Netherlands'. Under one rulebook, two very different market structures are forming.
Published: July 2026 · Data as of 24 July 2026 · Reading time: ~7 minutes
Key Takeaways
- 50 of the 308 authorised firms are credit institutions — about one entry in six.
- Banks do not apply for a CASP licence. Under MiCA Article 60 they notify their home regulator 40 working days before starting, because they are already authorised and supervised under the banking rulebook.
- Banks take narrower permissions: 2.2 services on average versus 3.6 for crypto-native firms. They favour execution of orders (71%) and largely avoid exchange services (12%, against 59%).
- The geography is extreme. Germany: 31 of 65 CASPs are banks (48%). France: 2 of 31 (6%). Netherlands: 1 of 29 (3%).
- Germany's cooperative sector runs an explicit hub-and-spoke model: 16 of its 17 listed banks hold execution only, while DZ BANK alone holds custody for the network.
The door banks use: Article 60
The single most important thing to understand about banks on the MiCA register is that they are not licensed as crypto-asset service providers at all.
Under Article 60 of Regulation (EU) 2023/1114, a credit institution may provide crypto-asset services by notifying the competent authority of its home member state at least 40 working days before it starts. The notification must include a programme of operations, internal control mechanisms, and its procedures for segregation of client assets, custody, anti-money-laundering and ICT risk. But it is a notification, not an application — there is no separate CASP authorisation to win.
The logic is straightforward: a bank has already cleared a far heavier prudential bar under the banking rulebook and is already supervised. MiCA layers the crypto-specific requirements on top rather than starting the assessment from scratch. The same route exists for investment firms, e-money institutions and UCITS managers.
Two consequences follow, and both matter when reading the register:
1. A bank appearing on the register is routine, not a milestone. Coverage that treats each one as a landmark is misreading the mechanism. 2. The barrier for an incumbent is operational, not regulatory. The question a bank faces is not "can we get authorised?" but "do we want to run this?" — which is why the service choices below are so revealing.
How many, and where
As of 24 July 2026 the register holds 312 records for 308 distinct firms. By our classification, 50 of those firms are credit institutions — one in six.
A caveat worth stating plainly: ESMA does not tag credit institutions in the register. There is no field marking a bank. Our count classifies by legal name (Bank, Banca, Banque, Banco, Sparkasse, Volksbank, Raiffeisenbank, Kreditbank and similar), so treat it as a close estimate rather than an official tally.
The distribution is where it gets interesting:
| Country | Banks | Total CASPs | Share |
|---|---|---|---|
| Germany | 31 | 65 | 48% |
| Spain | 6 | 13 | 46% |
| Liechtenstein | 4 | 12 | 33% |
| Luxembourg | 3 | 13 | 23% |
| Croatia | 1 | 6 | 17% |
| Italy | 1 | 9 | 11% |
| France | 2 | 31 | 6% |
| Netherlands | 1 | 29 | 3% |
Germany and France have comparable-sized registers built from almost opposite ingredients. Germany's crypto sector is being absorbed into its banking system; France's and the Netherlands' are dominated by crypto-native firms. Same regulation, same passport, entirely different market structure.
Bank entries arrived in waves rather than steadily:
| Quarter | Banks added |
|---|---|
| 2025 Q1 | 2 |
| 2025 Q2 | 7 |
| 2025 Q3 | 4 |
| 2025 Q4 | 16 |
| 2026 Q1 | 6 |
| 2026 Q2 | 10 |
| 2026 Q3 (to 24 Jul) | 5 |
The Q4 2025 spike is almost entirely the German cooperative sector moving as a bloc — eight banks were notified within a single fortnight in December 2025.
Banks want different things
This is the part the raw count hides. Banks and crypto-native firms register for measurably different permissions.
| Service | Banks | Crypto-native firms |
|---|---|---|
| Execution of orders | 71% | 41% |
| Custody and administration | 45% | 66% |
| Transfer services | 43% | 61% |
| Reception & transmission of orders | 24% | 22% |
| Exchange for funds | 12% | 59% |
| Exchange for other crypto-assets | 8% | 49% |
| Portfolio management | 4% | 16% |
| Operating a trading platform | 2% | 7% |
Banks average 2.2 services; crypto-native firms average 3.6.
The pattern is coherent. Banks are overwhelmingly registering to route client orders — execution, and to a lesser degree reception and transmission. They are largely not registering to run exchange or conversion businesses: 12% take exchange-for-funds against 59% of crypto firms, and only 2% operate a trading platform.
In plain terms: banks are not trying to become exchanges. They are plugging crypto into the brokerage rails they already run, so an existing customer can buy bitcoin the way they buy a fund — while the matching, market-making and conversion happen somewhere else in the chain.
Custody is the interesting middle case. At 45%, it is common but far from universal, and who takes it is not random.
The German cooperative model: sixteen spokes, one hub
Germany's cooperative banking network — the local Volksbanken and Raiffeisenbanken — accounts for 17 of the register's banks, and their permissions are almost uniform:
| Services held | Banks |
|---|---|
| Execution of orders only | 16 |
| Custody + execution + transfers | 1 (DZ BANK) |
DZ BANK is the central institution of the network — the shared infrastructure provider for roughly 700 local cooperative banks. It is the only one of the seventeen registered for custody.
Every other cooperative bank on the register — Hannoversche Volksbank, VR Bank Südpfalz, Volksbank Heiden, Raiffeisenbank Falkenstein-Wörth and the rest — holds execution and nothing else. A customer at a local branch can place a crypto order; the local bank routes it and never holds the asset.
The contrast with the rest of the sector is stark: among the 34 other credit institutions on the register, 22 hold custody. For the cooperative network it is 1 in 17.
That is deliberate design, not coincidence. Custody carries MiCA's heaviest obligations — segregation of client holdings, liability for loss, documented custody policies, key management. Concentrating it once, centrally, and letting 700 local banks stay on the light end of the rulebook is exactly how the cooperative sector already handles securities settlement and shared IT.
What this tells us about MiCA
MiCA was written to create a single market, and on paper it has: one authorisation, one passport, uniform rules. But the entrants differ so sharply by country that "the EU crypto market" is already a misleading phrase.
In Germany, crypto is arriving through the banking system — nearly half the register, a coordinated cooperative rollout, and a central institution carrying the custody burden for hundreds of local banks. In France and the Netherlands, the register is almost entirely crypto-native firms, and the banks have stayed out.
Whether that reflects different consumer demand, different supervisory posture, or simply different banking structures is not something the register can answer. What it does show is that a single rulebook has not produced a single market shape — and that the most consequential MiCA story is not who is authorised, but which services they chose to take.
Frequently Asked Questions
Do banks need a MiCA licence to offer crypto? No. Under MiCA Article 60 a credit institution notifies its home regulator at least 40 working days before providing crypto-asset services, supplying a programme of operations plus its custody, segregation, AML and ICT arrangements. It does not apply for separate CASP authorisation.
How many banks provide crypto services under MiCA? About 50 of the 308 authorised firms as of 24 July 2026 — roughly one in six. They include 17 German cooperative banks plus BBVA, KBC, Clearstream Banking, CACEIS, LGT, Bank Frick, Banca Sella, Swissquote, N26, Trade Republic and BNY SA/NV.
Which country has the most banks offering crypto? Germany by a wide margin: 31 of its 65 registered CASPs are credit institutions — 48% of the national register, against 6% in France and 3% in the Netherlands.
Do banks offer crypto custody? Some. About 45% of the banks on the register hold the custody permission, against 66% of crypto-native firms. The German cooperative network is a deliberate exception: only DZ BANK holds custody, for the whole network.
What services do banks avoid? Exchange services above all. Only 12% of banks registered for exchange of crypto-assets for funds, against 59% of crypto-native firms, and just 2% operate a trading platform.
Sources
- MICA Watch snapshot of the ESMA CASP register, data as of 24 July 2026. Browse the full register, the CASP hub, or profiles for Germany, Spain, Luxembourg and Liechtenstein.
- Regulation (EU) 2023/1114 (MiCA), Article 60 — provision of crypto-asset services by credit institutions on notification. Context: MiCA regulators and the EU framework.
- Service categories follow MiCA Annex I as published in the register's own `serviceCode` field.
- Bank classification is by legal name; ESMA does not tag credit institutions in the register.