Which MiCA authorisation do you need? A decision guide

Most MiCA guides tell you what the regulation says. This one shows what 324 authorised firms actually did — which services they applied for, where they authorised, and how narrow their permissions usually are. Work through the branches below and you will know which part of MiCA applies to you, and what the register says about firms who took the same route.

Published: August 2026 · Data as of 12 August 2026 · Reading time: ~8 minutes

> This is not legal advice. It is a map of the MiCA framework and a summary of the public register. Which authorisation a specific business needs depends on facts only a qualified adviser and your national regulator can assess.

Key Takeaways

  • The first fork is simple: are you issuing a crypto-asset, or providing a service around someone else's? Different titles of MiCA, different obligations.
  • Issuers split three ways: EMT (pegged to one currency), ART (pegged to a basket or other value), and everything else under Title II. The register shows 23 EMT issuers, 0 ART issuers, and 600 Title II offerors.
  • Service providers pick from ten services. Firms take just over three on average, and 66 of 324 hold exactly one. You apply for what you do — not for everything.
  • Already a bank, investment firm or e-money institution? You likely do not apply at all — MiCA Article 60 lets you notify instead, 40 working days ahead.
  • Minimum capital runs €50,000 to €150,000 depending on services (MiCA Annex IV), with the heaviest tier for operating a trading platform.

Fork 1: Are you issuing, or servicing?

Everything starts here.

If you create and offer a crypto-asset to the public — a token, a stablecoin, a coin for your platform — you are an issuer or offeror, and your obligations come from MiCA's Titles II, III and IV. The core duty is a crypto-asset white paper: a disclosure document notified to a national regulator.

If you handle other people's crypto-assets — running an exchange, holding custody, executing trades, moving assets between wallets — you are a crypto-asset service provider (CASP), and your obligations come from Title V. The core duty is authorisation by a national competent authority.

Many businesses are both. An exchange that also issues its own token needs both routes.

Fork 2 (issuers): Which kind of token?

MiCA does not care what you call your token. It classifies by what backs it, and the label decides which title applies.

Your tokenMiCA categoryOn the register
Pegged to one official currency (e.g. a euro stablecoin)E-money token (EMT), Title IV23 issuers, 43 white papers
Pegged to a basket — several currencies, commodities, other cryptoAsset-referenced token (ART), Title III0 issuers
Anything else — utility tokens, platform tokens, NFTs in scopeOther crypto-asset, Title II600 offerors, 960 white papers

Three things the register tells you that a rulebook cannot:

The ART register is empty. Not small — zero. Title III is the heaviest issuer regime in MiCA, and to date no one has taken it. If your design points toward ART, you would be the first, and you should treat that as a signal about cost. We looked at why in the empty ART register.

EMT is a small, institutional club. 23 issuers, heavily banks and payment institutions — Circle, Société Générale-Forge, Paxos, CACEIS. It is a licensing-grade undertaking, not a launch.

Title II is where the volume is. 600 offerors. This is the default path for most tokens, and the obligation is disclosure rather than authorisation.

The full classification test, with the edge cases, is in EMT vs ART under MiCA.

Fork 3 (service providers): Which of the ten services?

MiCA lists ten crypto-asset services. You apply for the ones you actually provide, and the register shows firms are selective — the average is just over three, and 66 firms hold exactly one.

MiCA serviceFirms holding itShare
Custody & administration20162%
Transfer services19259%
Exchange for funds16651%
Execution of orders15548%
Exchange for other crypto-assets13642%
Reception & transmission of orders7924%
Portfolio management4614%
Advice3511%
Placing3410%
Operating a trading platform206%

Two traps worth naming.

"Exchange" is two different licences. If clients trade against each other on your order book, that is operating a trading platform — the rarest and heaviest authorisation, held by just 20 firms. If you are the counterparty, selling from your own book, that is exchange for funds — held by 166. Most consumer "crypto exchanges" in the EU hold the second, not the first. We unpacked the distinction in only 20 of 324 MiCA firms can run a crypto exchange.

Custody is the dividing line for obligations. At 62% it is the most common service, but it carries MiCA's heaviest operational duties — segregating client assets, liability for loss, custody policies, key management. Germany's cooperative banks show the alternative strategy plainly: 16 of the 17 on the register took execution only and left custody to their central institution. See banks and MiCA.

Fork 4: Are you already a regulated firm?

This one saves the most work, and it is the most missed.

Under MiCA Article 60, an entity already authorised under EU financial-services law — a credit institution, investment firm, e-money institution, UCITS manager or AIFM — may provide crypto-asset services without applying for a separate CASP authorisation. It notifies its home regulator at least 40 working days before starting, supplying a programme of operations, internal controls, and its custody, segregation, AML and ICT arrangements.

The register shows how much this is used: roughly one entry in six is a credit institution — around 50 of the 324 firms.

If you already hold a licence, your first question is not "how do I get authorised?" but "does Article 60 cover me?"

Where to authorise

A MiCA authorisation passports across the whole EU and EEA, so the member state you choose is an operational decision, not a market-access one. The register shows where firms went:

CountryAuthorised firms
Germany70
France34
Netherlands29
Cyprus25
Malta22
Spain15
Luxembourg13
Ireland12

The concentrations are not random, and they say different things. Germany's register is nearly half banks. Malta hosts the global consumer exchanges — OKX, Crypto.com, Gemini, Gate. Ireland has only 12 CASPs but is first in the EU for white-paper notifications. Country-by-country detail sits on our regulators page and the per-country profiles: Germany, France, Malta, Ireland.

One caution against picking purely for speed: ESMA's first MiCA peer review, published July 2025, criticised one regulator for authorising ahead of others with material issues unresolved. Fast is not the same as durable.

What it costs, prudentially

MiCA sets a permanent minimum capital requirement by service class in Annex IV, ranging from €50,000 to €150,000. The lightest tier covers advisory and order-transmission style services; operating a trading platform sits at the top.

The requirement is not just that headline figure. Under Article 67, a CASP must hold prudential safeguards equal to the higher of the Annex IV minimum or one quarter of the preceding year's fixed overheads — and it can be met with own funds, an insurance policy, or a comparable guarantee. A firm with substantial running costs will be held to the overheads calculation, not the floor.

National fee schedules sit on top of this and vary widely; France is unusual in publishing flat figures.

The cost of getting it wrong

MiCA is enforced. The register of non-compliant entities — firms named publicly for providing crypto services without authorisation — holds 167 entries. The distribution is lopsided because it reflects one regulator's method rather than where the activity is, which we examined in why Italy holds almost all of them.

Frequently Asked Questions

Do I need a MiCA licence to issue a token? Not an authorisation, in most cases. Issuers of ordinary crypto-assets under Title II publish a crypto-asset white paper and notify a national regulator — a disclosure duty, not a licence. Issuers of asset-referenced tokens (Title III) and e-money tokens (Title IV) face authorisation-grade regimes.

How many services should I apply for? Only those you provide. The register average is just over three of the ten, and 66 of 324 firms hold exactly one. Each additional service adds obligations and can raise your capital class.

I already have a banking or investment-firm licence. Do I need a CASP authorisation? Probably not. MiCA Article 60 lets credit institutions, investment firms, e-money institutions, UCITS managers and AIFMs provide crypto-asset services on 40 working days' notification instead of a fresh authorisation. About one in six firms on the register is a credit institution.

What is the minimum capital for a MiCA CASP? Between €50,000 and €150,000 depending on the services, set by class in MiCA Annex IV. Under Article 67 the actual requirement is the higher of that figure or one quarter of the previous year's fixed overheads.

Does it matter which country I authorise in? Not for market access — a MiCA licence passports across the EU and EEA. It matters for supervisory approach, timelines, fees and language. Germany, France, the Netherlands, Cyprus and Malta host the largest registers.

Sources

  • MICA Watch snapshot of the ESMA registers, data as of 12 August 2026: 324 authorised CASPs, 23 EMT issuers, 0 ART issuers, 600 Title II offerors, 167 non-compliant entries. Browse the full register or the CASP hub.
  • Regulation (EU) 2023/1114 (MiCA): Title II (crypto-asset white papers), Title III (ARTs), Title IV (EMTs), Title V (CASP authorisation and services), Article 60 (provision of services by already-authorised entities), Article 67 and Annex IV (prudential requirements).
  • ESMA peer review of a national competent authority's MiCA authorisation process, published 10 July 2025.
  • Competent authorities by member state: MiCA regulators.