39% of MiCA-licensed firms never use the EU passport

MiCA's headline promise is one licence, valid across the whole European Union and EEA. The register shows how many firms actually take it up — and the answer is that a large share never leave home. 125 of 324 authorised providers passport to one country or none, and the newer the licence, the narrower the footprint. This is what a single market looks like when half the participants only need a local one.

Published: August 2026 · Data as of 12 August 2026 · Reading time: ~7 minutes

Key Takeaways

• Of 324 authorised CASPs, 125 (39%) passport to one country or none. The median firm reaches 11 countries; the maximum — full EU/EEA coverage — is 30, reached by 89 firms.
• The distribution is bimodal, not spread: 46% passport to five countries or fewer, 46% to 26 or more, and only 8% sit anywhere in between.
• The trend is downward. Across our snapshot archive, average passporting fell from 19.9 countries in July 2025 to 15.0 now as the register grew.
• Newer cohorts use the passport less. Firms authorised in 2025 average 17.5 countries; those authorised in 2026 average 12.8. The share passporting widely flipped from 55% to 38%.
• The mechanism is who joined: banks average 7.1 countries (72% of them narrow), crypto-native firms 16.8. As institutions entered, the aggregate footprint shrank.

Two Europes in one register

MiCA's passport works like the rest of EU financial regulation: authorisation in one member state, and the right to serve clients in all the others by notifying the regulator. The register records which countries each firm has notified — so we can see who exercises the right and who leaves it on the shelf.

The answer is not a gradient. It is two clusters:

Just 8% of firms sit anywhere in the middle. The rest are either essentially domestic or essentially pan-European. There is no gradual expansion path visible in the data — firms appear to decide early whether Europe is their market, and act accordingly.

The named examples make the split concrete. At the top, reaching all 30 EEA states: Coinbase and Bitstamp (Luxembourg), Kraken and Ramp Network (Ireland), Bitvavo and One Trading (Netherlands), Clearstream and Standard Chartered (Luxembourg), Paybis (Latvia), Trade Republic and Bitpanda. At the bottom, on one country: DZ BANK, Hannoversche Volksbank, several Raiffeisenbanken, CaixaBank, Banca Sella.

The passport is being used less over time

This is the part only a snapshot archive can show. ESMA overwrites its register without keeping history, so the trend is invisible from the live file. We have kept dated copies since July 2025.

Average reach fell by a quarter as the register grew sevenfold. Note what this is not: it is not firms retreating. Individual firms mostly hold their footprint or expand it — 58 CASPs increased the number of countries they passport to over the period, some from a single country to thirty.

The average fell because of who arrived, not because anyone left.

The cohort flip

Split the register by the year a firm was authorised and the change is unambiguous:

The majority position inverted. Among 2025 entrants, most firms took Europe; among 2026 entrants, most stayed home.

The first wave was self-selecting: getting licensed early, before the transitional deadlines bit, was something pan-European crypto platforms did because EU-wide access was the point. The later wave is broader and more local.

Why: the institutions arrived

The single clearest driver is the entry of credit institutions, which we looked at in banks and MiCA.

A German cooperative bank adding crypto execution for its existing local customers has no use for Portuguese passporting. It is not failing to exploit the single market; it is serving the market it has. Of the 125 firms passporting to one country or none, 54 are German — overwhelmingly the regional and cooperative banks.

Trade Republic, also German, passports to all 30. The split is not national character; it is business model.

Export hubs and domestic markets

Aggregate by home state and two distinct roles appear.

Licence-as-export-hub — small jurisdictions whose firms serve the continent:

Domestic markets — larger economies whose firms mostly serve home:

Luxembourg is the sharpest case: 13 firms, averaging 29.5 of a possible 30. Nobody licenses in Luxembourg to serve Luxembourg. Germany is the mirror image — the largest register in the EU, and an average reach of under six countries.

This also reframes the "which country should I authorise in" question. Germany's 70 licences signal a deep domestic market; Luxembourg's 13 signal an export platform. Same passport, opposite purpose. (See which MiCA authorisation do you need and the regulators overview.)

What it means

Read carelessly, "39% don't use the passport" sounds like a verdict on MiCA. It isn't. The passport is optional infrastructure, and the data shows precisely who needs it: platforms competing for European users take all 30 states; institutions serving existing local customers take one.

What the numbers do challenge is the idea that MiCA produced a single, uniform European crypto market. It produced one rulebook serving two different businesses — and as the register fills with the second kind, the aggregate looks less pan-European each quarter, even while individual firms expand.

For anyone reading register totals as a measure of market integration, that distinction matters. Counting licences tells you how many firms are regulated. Counting passports tells you how many are actually competing across borders — and that number is a minority.

Frequently Asked Questions

What is MiCA passporting? A firm authorised as a CASP in one EU member state can provide its services in every other EU and EEA state by notifying its regulator, without a second licence. The register records which countries each firm has notified.

How many countries can a MiCA licence cover? 30 — the 27 EU member states plus Iceland, Liechtenstein and Norway. 89 firms hold full coverage, and 149 reach 26 or more.

Do most MiCA firms operate across the EU? No. 125 of 324 authorised firms (39%) passport to one country or none, and 46% reach five or fewer. Only 46% reach 25 or more.

Which country's firms passport the most widely? Luxembourg, averaging 29.5 countries across 13 firms, followed by Latvia (26.2), Ireland (25.4) and Cyprus (21.8). The narrowest are Czechia (1.5), Germany (5.7) and Italy (5.8).

Why is average passporting falling? Composition, not retreat. Firms authorised in 2026 average 12.8 countries against 17.5 for the 2025 cohort, because credit institutions serving domestic customers now make up a larger share of new entrants. 58 individual firms actually expanded their footprint over the period.

Sources

• MICA Watch snapshot archive of the ESMA CASP register, 11 July 2025 – 12 August 2026 (16 dated snapshots). ESMA publishes the register as an overwrite without a public archive, so the time series is our own. Browse the CASP register or the full entity list.
• Passporting figures from the register's `serviceCode_cou` field, aggregated per firm (by LEI where present). One data-quality note: the register codes Greece inconsistently as both `EL` (the EU's code) and `GR` (ISO 3166-1), so a raw count credits some firms with 31 countries out of a possible 30. We merge the two before counting; the figures above are de-duplicated. Credit-institution classification is by legal name; ESMA does not tag it.
• Regulation (EU) 2023/1114 (MiCA), Title V — authorisation and cross-border provision of crypto-asset services.
• Related: CASP services and passporting, banks and MiCA, country profiles for Germany and Luxembourg.