European Union — License Map

The European Union operates the world's most comprehensive crypto-asset regulatory framework through the Markets in Crypto-Assets Regulation (MiCA), Regulation (EU) 2023/1114. MiCA is a directly applicable regulation across all 27 EU member states plus EEA countries, providing a single licensing passport for crypto-asset service providers. This page consolidates the licensing landscape across custody, stablecoin issuance, and mining/staking, highlighting cross-cutting costs, synergies, and strategic considerations that no single-domain analysis provides.

Regulatory Architecture

Unified Framework, Multiple Supervisors

MiCA entered into force in stages: stablecoin provisions (Titles III and IV) from 30 June 2024, CASP authorization (Title V) from 30 December 2024, and full enforcement (end of all grandfathering) on 1 July 2026.

Key NCAs: BaFin (Germany), AFM/DNB (Netherlands), AMF/ACPR (France), MFSA (Malta), CSSF (Luxembourg), CBI (Ireland).

Complementary Legislation

MiCA does not operate in isolation. Firms must also comply with:

• DORA (Digital Operational Resilience Act) -- ICT risk management, incident reporting, resilience testing
• TFR (Transfer of Funds Regulation) -- crypto Travel Rule, no de minimis threshold
• AMLR (applicable July 2027) -- harmonized AML/CFT obligations
• PSD2/PSD3 -- payment services interplay for EMT custody and transfers
• CSRD -- sustainability reporting for large entities
• DAC8 -- crypto tax reporting from 1 January 2026

Activity Comparison Table

Multi-Activity Licensing in the EU

Can One Entity Hold Multiple Authorizations?

Yes. MiCA's CASP authorization framework is modular -- an entity applies for authorization covering one or more of ten enumerated crypto-asset services. A single entity can hold:

• CASP authorization covering custody, exchange, and trading platform operation (Class 3 at EUR 150,000 minimum covers all CASP services)
• EMI license (under the E-Money Directive) or credit institution license for stablecoin issuance
• PSD2 authorization for payment services involving EMT transfers (may be required from March 2026)

How Combined Licensing Works

Custody + Exchange (single CASP license): A single CASP Class 3 authorization at EUR 150,000 minimum capital covers custody, exchange, and trading platform operation. There is no need for separate licenses per service -- the capital requirement is the highest applicable class.

Custody + Stablecoin Issuance (separate licenses required): CASP authorization (for custody) and EMI/ART authorization (for issuance) are governed by different titles of MiCA and different underlying directives. An entity must hold both. However, credit institutions already authorized under CRD can provide both custody services (via simplified CASP notification) and issue EMTs (via notification + white paper), avoiding dual-application processes.

The Credit Institution Advantage: Banks holding a CRD banking license benefit from the most streamlined path. They can:

1. Notify their NCA to provide CASP services (40 working days, no separate authorization)
2. Notify their NCA and submit a white paper to issue EMTs or ARTs (no separate authorization)
3. Custody their own stablecoin reserves (self-custody permitted for credit institutions)

This makes a credit institution the most capital-efficient multi-activity license in the EU, though the entry cost for a banking license far exceeds CASP + EMI combined.

Cost Savings from Shared Infrastructure

Firms pursuing multiple activities can realize savings on:

• Shared compliance function: One CCO and MLRO covering both CASP and EMI obligations (EUR 120,000--250,000/year instead of EUR 240,000--500,000)
• Single physical office and EU-resident director: EUR 39,000--50,000/year shared across activities
• Shared AML/KYC systems: EUR 30,000--100,000/year once, not duplicated
• Single DORA compliance program: EUR 10,000--30,000/year covering all regulated activities
• Combined audit: Potential savings of EUR 10,000--20,000/year versus separate statutory audits

Consolidated Banking Access

Banking access is the single most critical practical challenge across all three activities. The situation varies by activity type:

Banks Known to Serve Licensed Crypto Entities

Banking Reality by Activity

• Custody CASPs: 3--6 month onboarding for licensed entities; MiCA requires client fiat to be placed with a credit institution by next business day (Art. 70)
• Stablecoin issuers: Must hold at least 30% of reserves (60% for significant tokens) at credit institutions; BNY Mellon, GSIB banks, and the euro stablecoin consortium Qivalis (37 banks across 15 countries by 21 May 2026) signal growing institutional engagement
• Mining operations: Near-impossible banking access without a CASP license; even licensed miners report extended onboarding timelines

Key statistic: Only 14% of crypto companies report seamless banking onboarding. The EBA has identified debanking as a "top 3" issue for EU consumers in the crypto sector. Germany has the strongest cluster of crypto-friendly banking infrastructure (6+ banks actively serving crypto entities).

Total Cost Estimate: Multi-Activity Operation

Scenario: Custody + Stablecoin Issuance from the EU

Year 1 Setup:

Annual Ongoing (Year 2+):

Savings from combining: Approximately EUR 150,000--300,000/year versus running fully separate operations, primarily from shared compliance staff, single office, shared technology stack, and combined audit.

MiCA Passporting Advantage

The single most compelling reason to license in the EU is the MiCA passport (Article 65):

How It Works

1. Obtain CASP or issuer authorization in one member state
2. Notify home NCA of intention to provide cross-border services
3. Home NCA communicates the notification to host NCAs within 5 working days (MiCA Article 65)
4. Commence services in target member states approximately 15 calendar days after notification
5. No separate authorization, application fee, or physical presence required in host states

What the Passport Covers

• 27 EU member states + EEA (Norway, Iceland, Liechtenstein) -- approximately 450 million consumers
• All crypto-asset services for which the CASP is authorized
• Both CASP services (custody, exchange) and token offerings (EMTs, ARTs)

Practical Limitations

• Grandfathered firms cannot passport -- only full MiCA authorization unlocks cross-border rights
• Host state marketing rules still apply -- consumer protection requirements vary by member state
• "Gold-plating" -- Germany, France, and Poland have imposed de facto local substance requirements for firms with significant local operations
• Regulatory arbitrage concern: France's AMF, Austria's FMA, and Italy's CONSOB jointly proposed direct ESMA supervision of significant CASPs (September 2025), signaling that the passport's uniformity may be tightened
• Third-country firms have no passport rights -- non-EU entities must establish an EU-authorized entity

Strategic Jurisdiction Choice

Regulatory Direction

Near-Term (2026--2027)

• 1 July 2026: End of all transitional periods -- full MiCA enforcement. Unauthorized CASPs must cease operations or implement orderly wind-down
• March 2026: PSD2 dual-licensing deadline for EMT transfer services. CASPs handling stablecoin transfers may need separate payment services authorization
• 2026: EBA second annual significance assessment for EMTs/ARTs. USDC is the most likely candidate for significant token designation
• Q2 2026: First coordinated cross-border CASP audit by AMLA
• 1 July 2027: AMLR takes full effect -- directly applicable harmonized AML/CFT obligations, ban on anonymous crypto accounts and privacy tokens

Medium-Term Trends

• MiCA review ("MiCA 2.0"): On 20 May 2026 the European Commission opened a targeted public consultation on the review of MiCA (open until 31 August 2026), reopening the stablecoin interest/remuneration ban (Articles 40, 50), reserve/significance-threshold calibration, multi-issuance of fungible tokens (e.g. USDC), a possible third-country equivalence regime, the ban on listing non-MiCA-compliant stablecoins (e.g. USDT), and the treatment of DeFi, staking, lending and tokenized assets / NFTs. Under MiCA Article 140, the Commission's review report (potentially with a legislative proposal) is due by 30 June 2027; concrete legislative text is expected only in 2027-2028
• Centralized supervision push: AMF/FMA/CONSOB position paper advocates direct ESMA supervision of significant CASPs
• Interest prohibition debate: The blanket ban on stablecoin yield (Articles 40, 50) faces growing criticism as the US GENIUS Act (Public Law 119-27, signed 18 July 2025) advances; it is now explicitly on the table in the 20 May 2026 MiCA 2.0 consultation. Amendment possible within 2--3 years
• EU Taxonomy for mining: Commission mandate to classify crypto mining as environmentally significant activity remains partially undelivered
• Traditional bank entry: The euro stablecoin bank consortium — the Amsterdam-based JV named Qivalis (December 2025), to be licensed as an EMI by De Nederlandsche Bank (DNB) — had expanded from nine founders (ING, UniCredit, SEB, CaixaBank, and others) to 37 banks across 15 countries by 21 May 2026, with launch targeted for H2 2026, signalling institutional consolidation
• Sustainability disclosure escalation: Commission Delegated Regulation (EU) 2025/422 (effective December 2025) significantly increases environmental reporting burden for all crypto activities

Enforcement Trends

• Over EUR 540 million in penalties since MiCA enforcement began
• 230+ audits conducted in H1 2025
• 50+ license revocations through February 2025
• France issued a EUR 62 million single-platform penalty -- largest MiCA fine to date
• Two CASPs fined EUR 12M and EUR 8M respectively for Travel Rule violations
• ESMA has warned that last-minute applications face heightened scrutiny and unauthorized CASPs must implement wind-down plans

Key Risk: EU Crypto Workforce Contraction

The EU crypto workforce has contracted sharply -- from over 100,000 blockchain-related jobs in 2022 to approximately 10,000 in 2025 -- partly attributed to regulatory pressure and compliance costs. An estimated 75% of pre-existing EU VASPs could lose compliance status when grandfathering periods expire, suggesting significant market consolidation ahead.

Mining-Specific Considerations

While MiCA does not directly regulate or ban crypto mining, the EU's approach creates a unique regulatory environment that affects mining operations through multiple indirect channels.

No PoW Ban, But Disclosure Requirements

The European Parliament rejected a proposed PoW ban in March 2022 (30-23 vote). MiCA adopted a disclosure-based approach instead:

• Token white papers must include environmental impact of the consensus mechanism
• CASPs must display sustainability information on websites
• Enhanced disclosure required when annual energy consumption exceeds 500,000 kWh
• Commission Delegated Regulation (EU) 2025/422 (effective December 2025) specifies detailed content, methodologies, and presentation for sustainability disclosures
• The Commission was mandated to propose inclusion of crypto mining in the EU Taxonomy for Sustainable Activities by January 2025 -- this remains partially undelivered but the direction is clear

De Facto Mining Licensing: Energy and Environmental Permits

Since pure mining has no crypto-specific license, the real licensing barriers for industrial mining in the EU are:

• Energy permits: Industrial electricity connections exceeding 1 MW require grid connection permits from national transmission/distribution system operators. Permitting can take months to years depending on member state
• Environmental Impact Assessment (EIA): Operations exceeding certain energy, noise, or emission thresholds trigger EIA requirements under Directive 2011/92/EU
• CSRD reporting: Large mining companies meeting thresholds (more than 250 employees, more than EUR 50M revenue, or more than EUR 25M assets) must report under European Sustainability Reporting Standards using double materiality

Energy Economics Make Most of Western Europe Uneconomical

European industrial electricity rates range from EUR 0.10--0.35/kWh, well above the general mining profitability threshold of below EUR 0.10/kWh. Viable locations are limited to:

• Nordic countries: EUR 0.03--0.08/kWh (hydro/geothermal), but Norway has banned new mining data centers and Sweden/Iceland impose capacity caps
• France: EUR 0.08--0.15/kWh (nuclear)
• Eastern Europe: Varying rates
• Germany, Italy, Denmark, Ireland: EUR 0.25--0.35/kWh -- uneconomical for mining

National Fragmentation

Despite MiCA harmonization, mining-specific rules remain nationally fragmented:

When Mining Triggers CASP Licensing

Mining alone does not require MiCA authorization, but several common mining-adjacent activities do:

• Mining pool operation -- offering pooled hashrate services to third parties may constitute a crypto-asset service
• Hashrate sales / cloud mining -- selling hashrate contracts or hosting mining for clients is likely a regulated service
• Custodial mining -- holding mined assets on behalf of others triggers custody licensing (CASP Class 2, EUR 125,000 minimum)
• Token issuance -- issuing tokens backed by mining output (e.g., tokenized hashrate) triggers white paper and issuer obligations

Transition Timeline and Key Dates

Tax Reporting Obligations

DAC8 — EU Crypto-Asset Reporting Framework

Council Directive (EU) 2023/2226, known as DAC8, is the EU's mandatory crypto tax reporting regime. It applies from 1 January 2026, with the first exchange of information between member state tax authorities due by 30 September 2027.

Reporting Entities

DAC8 reporting obligations fall on Reporting Crypto-Asset Service Providers (RCASPs) — entities authorized under MiCA to provide crypto-asset services. This includes exchanges, brokers, custodians, and transfer facilitators. MiCA authorization is the mechanism that identifies the reporting population: any entity holding a CASP license is automatically within DAC8's scope.

Information Reported

RCASPs must collect and report to national tax authorities:

• Taxpayer identification: name, address, TIN (tax identification number), date of birth
• Aggregate transaction data: gross amounts of purchases and sales against fiat currency, aggregate market values of crypto-to-crypto exchanges
• Asset designation: the specific designation of each crypto-asset traded
• Transaction volume: units and number of transactions per reportable period

National tax authorities then automatically exchange this information with the tax authority of the member state where the customer is resident.

Customer Blocking Provision

DAC8 introduces the most aggressive customer enforcement mechanism globally: if a customer fails to provide self-certification (confirming tax residency and TIN) after two reminders, the RCASP must block the customer from performing reportable transactions within 60 days. This provision has no equivalent in the OECD CARF framework and effectively cuts off non-compliant users from the regulated EU crypto ecosystem.

Penalties

DAC8 establishes a penalty framework of EUR 20,000 to EUR 500,000 for the most serious non-compliant behavior (such as complete absence of reporting despite administrative reminders). Member states retain discretion over specific penalty structures within this range.

Transposition Status (as of March 2026)

On 30 January 2026, the European Commission launched formal infringement procedures against 12 member states that had not notified national measures transposing DAC8 into domestic legislation. These member states were sent letters of formal notice, with approximately a two-month deadline to respond.

CARF Alignment

DAC8 is closely aligned with the OECD Crypto-Asset Reporting Framework (CARF), both requiring aggregate transaction reporting rather than year-end balance snapshots. As of late 2025, 76 jurisdictions have committed to implementing CARF, with first exchanges expected in 2027--2028. DAC8 goes further than CARF in three respects: extraterritorial reach (applies to non-EU platforms serving EU residents), the customer blocking provision, and mandatory GDPR notifications before data collection.

Interaction with MiCA — The Licensing-Taxation Nexus

MiCA and DAC8 operate in tandem as of 1 January 2026, creating a licensing-taxation nexus:

1. MiCA licensing creates the reporting infrastructure: CASP authorization under MiCA requires KYC/AML procedures, transaction record-keeping, and supervisory reporting -- all of which feed directly into DAC8 reporting capabilities
2. DAC8 leverages the MiCA register: the ESMA CASP register identifies every authorized service provider, giving tax authorities a definitive list of reporting entities
3. Dual enforcement: non-compliance with DAC8 reporting can trigger penalties under DAC8 (EUR 20,000--500,000) and separately risk license revocation under MiCA. CASPs face a compliance imperative from both frameworks simultaneously
4. Shared definitions: DAC8 references MiCA's definitions of crypto-assets (ARTs, EMTs, and other crypto-assets), ensuring regulatory consistency between market conduct and tax reporting

Compliance Costs for DAC8 Reporting

DAC8 compliance adds to the already significant MiCA compliance burden:

• Technology and systems: RCASPs must implement or upgrade reporting systems capable of collecting TINs, aggregating transaction data, generating XML reports in the prescribed format, and transmitting them to national tax authorities. Estimated at EUR 5,000--10,000/year for existing MiCA-compliant CASPs with shared infrastructure
• GDPR overlay: unlike CARF, DAC8 requires GDPR notifications to customers before collecting and reporting personally identifiable information, adding data protection compliance costs
• Customer onboarding friction: the self-certification requirement and 60-day blocking provision require updates to onboarding flows, reminder systems, and account restriction mechanisms
• Multi-jurisdiction complexity: CASPs passporting across multiple EU member states must track varying national transposition timelines and penalty structures, particularly given that 12 member states face infringement proceedings for late transposition

RWA / Security Token Platform Licensing

The EU's framework for tokenized real-world assets operates through a classification-driven dual regime: tokenized assets qualifying as financial instruments under MiFID II fall under existing securities legislation, while non-financial-instrument crypto-assets are governed by MiCA. The DLT Pilot Regime (Regulation EU 2022/858) provides a dedicated pathway for DLT-based market infrastructures.

License Details

Requirements

Application Process

Ongoing Obligations

• MiFID II reporting, transaction reporting, best execution, product governance
• DORA (Digital Operational Resilience Act) ICT risk management and incident reporting
• TFR (Transfer of Funds Regulation) Travel Rule compliance
• DLT Pilot operators: compensatory measures for any exemptions granted; transition strategy
• DAC8 tax reporting obligations from 1 January 2026

Passporting

Full EEA passporting for MiFID II-authorized investment firms via freedom of services or branch establishment. DLT Pilot authorizations valid across the EU. CASP passport available for MiCA-authorized entities (27 EU + EEA states, ~450 million consumers).

Banking Access

MiFID II-authorized firms dealing in tokenized securities have established banking relationships and moderate onboarding difficulty. DLT Pilot operators (21X AG, 360X AG) benefit from institutional credibility. Credit institutions can combine tokenized securities activities with existing banking operations under a single authorization.

Key Holders

Transition

The DLT Pilot Regime is being made permanent through the 2026 Market Integration and Supervision Package. Proposed changes include raising aggregate thresholds from EUR 6 billion to EUR 100 billion, expanding eligible asset classes to all financial assets, and allowing MiCA-authorized CASPs to operate DLT trading venues. Trilogue negotiations expected through late 2026--2027; implementation anticipated 2027--2029.

See

DeFi Protocol Licensing

Regulatory Approach

The EU regulates DeFi through the MiCA CASP framework, with a critical carve-out: Recital 22 of MiCA states that crypto-asset services provided in a "fully decentralised manner without any intermediary" are outside MiCA's scope. However, this exemption has not been tested in practice, and ESMA has signaled that most protocols with identifiable development teams, governance token holders, or front-end operators will be treated as intermediated.

Available License Types

DeFi-Specific Requirements

• Smart contract audits: Not explicitly mandated by MiCA but required under DORA (Digital Operational Resilience Act) ICT risk management obligations for all CASPs. Third-party ICT service providers (including smart contract auditors) are subject to DORA oversight framework.
• Governance framework: MiCA requires CASPs to have robust governance arrangements (Art. 68). DAO governance structures may need to identify a "management body" for regulatory purposes. The Tornado Cash prosecution in the Netherlands (Alexey Pertsev conviction, May 2024) established precedent for developer criminal liability.
• Decentralization threshold: Recital 22 provides a "fully decentralised" exemption but defines no bright-line test. The Joint EBA-ESMA Report on recent developments in crypto-assets under Article 142 (ESMA75-453128700-1391, January 2025) analysed DeFi; the Commission's broader MiCA review under Article 140 is now live as the 20 May 2026 "MiCA 2.0" consultation (open until 31 August 2026), which expressly canvasses whether to extend MiCA to DeFi, lending and staking. The Commission's review report is due by 30 June 2027.
• Product Liability Directive (PLD) 2024/2853: Effective from December 2026, this directive extends product liability to software, potentially making DeFi smart contract developers liable for defects causing damage.

Key Licensed Operators

Application Timeline

• CASP authorization: 3--12 months (fast-track for pre-regulated entities: 3--4 months; new entrants: 9--12 months)
• MiFID II authorization: 6--18 months
• Grandfathering deadline: 1 July 2026 (all existing providers must hold full MiCA authorization)

Cross-Reference

See

Sources: MiCA Regulation (EU) 2023/1114, Recital 22; ESMA — Markets in Crypto-Assets Regulation (MiCA); European Commission — Commission seeks feedback on functioning of EU crypto-assets rules (20 May 2026); PLD Directive 2024/2853

Insurance / Risk Transfer Licensing

Overview

The EU's approach to digital asset insurance is embedded within MiCA itself. Article 67 of MiCA provides that CASPs may satisfy certain prudential requirements through insurance or a comparable guarantee as an alternative to holding additional own funds. This "insurance-as-alternative" mechanism is unique globally -- no other major jurisdiction has codified insurance as a regulatory capital substitute for crypto service providers. Separately, insurers writing digital asset policies in the EU must comply with the Solvency II Directive, and insurance intermediaries must comply with the Insurance Distribution Directive (IDD).

Regulatory Authority

MiCA Article 67: Insurance as Capital Alternative

MiCA Article 67 permits CASPs to reduce their minimum own funds requirement by obtaining professional indemnity insurance (PII) or a comparable guarantee. Key parameters:

Insurance Provider Licensing (Solvency II)

Entities seeking to underwrite digital asset insurance in the EU require:

• Solvency II authorisation from their home member state NCA (e.g., BaFin, ACPR, DNB)
• Passporting rights under the Freedom of Services or Freedom of Establishment provisions -- an insurer authorised in one member state can write policies across the EU/EEA
• IDD compliance for intermediaries (brokers, agents) distributing digital asset insurance products

Insurance Requirements for Crypto Businesses

Named Insurance Providers Active in the EU

Estimated Insurance Costs for EU CASPs

Regulatory Direction

• ESMA's Article 67 RTS will become the de facto standard for PII in the crypto sector across the EU
• The AMLA (from 2027) may introduce additional insurance expectations for high-risk CASPs under direct EU-level supervision
• Munich Re and other European reinsurers are expanding digital asset capacity, signalling growing market maturity
• The DLT Pilot Regime operators may face additional insurance requirements as the regime becomes permanent
• No expansion of DGSD to cover crypto assets is under active consideration

Cross-Reference

See

NFT & Digital Collectibles

Activity type: NFT marketplace operation, NFT issuance, fractionalized NFT platforms

Payment / Transfer Service License

Overview

The EU's crypto payment licensing framework operates through a dual-licence architecture: MiCA governs crypto-asset services (custody, exchange, trading), while PSD2/EMD2 (soon PSD3/PSR) governs payment services involving e-money tokens (EMTs). From 2 March 2026, CASPs providing EMT transfer and custody services must hold both MiCA authorization and PSD2 payment services authorization (per the EBA No-Action Letter of 10 June 2025 and follow-up Opinion of 12 February 2026). PSD3/PSR — whose final trilogue compromise texts were endorsed by COREPER on 22 April 2026 (Council texts published 23 April 2026) — will absorb EMD2 and offer a simplified authorization pathway for MiCA-licensed CASPs; Official Journal publication is anticipated June/July 2026 (may slip to September), with PSD3 carrying an 18-month transposition period.

License Details

Requirements

Application Process

Ongoing Obligations

Passporting & Cross-Border

Banking Access

Key License Holders

Transition / Grandfathering

Cross-Reference

See

Sources: MiCA Regulation (EU) 2023/1114; EBA No-Action Letter on PSD2/MiCA interplay (June 2025); PSD2 Directive (EU) 2015/2366; EMD2 Directive 2009/110/EC; ESMA Interim MiCA Register

Licensing Developments Since 2026-03-20

• 20 May 2026 — Commission opens "MiCA 2.0" review consultation (Article 140). The European Commission launched a targeted public consultation on the review of MiCA (open until 31 August 2026), reopening the stablecoin interest/remuneration ban (Articles 40, 50), reserve/significance calibration, multi-issuance of fungible tokens, a possible third-country equivalence regime, the ban on listing non-MiCA-compliant stablecoins, and the treatment of DeFi, staking, lending, tokenized assets and NFTs. Commission review report (potentially with a legislative proposal) due by 30 June 2027. Source: European Commission
• 22-23 April 2026 — PSD3/PSR final compromise texts endorsed by COREPER. The Council's Committee of Permanent Representatives endorsed the final trilogue compromise texts of PSD3 and PSR (Council "I" Item Note dated 17 April 2026); texts published 23 April 2026, now proceeding to European Parliament second-reading approval and legal-linguistic review. OJ publication anticipated June/July 2026 (may slip to September); PSD3 18-month transposition, PSR applies ~21 months after entry into force. This advances the simplified payment-authorization pathway for MiCA-licensed CASPs. Source: Regulation Tomorrow — Council issues "I" Item Note on PSD3 (April 2026)
• April-May 2026 — ESMA register passes ~199-204 authorized CASPs. As of 12 April 2026 the ESMA Interim MiCA Register listed ~199 authorized CASPs across ~23 EEA states (plus 20 EMT issuers, 0 ART issuers), rising to ~204 by 22 May 2026 (~51 authorized in 2026 alone); register last updated 29 May 2026. On 17 April 2026 ESMA confirmed the transitional regime ends uniformly on 1 July 2026 regardless of national status. Source: ESMA — Markets in Crypto-Assets Regulation (MiCA)
• 21 May 2026 — Euro-stablecoin bank consortium (Qivalis) expands to 37 banks. The Amsterdam-based JV Qivalis (named December 2025; to be licensed as an EMI by De Nederlandsche Bank) expanded from nine founders to 37 banks across 15 countries, with launch targeted for H2 2026. Source: CaixaBank — Qivalis to Launch Euro Stablecoin in H2 2026
• DLT Pilot Regime — six authorizations as of June 2026. Per ESMA's register of authorised DLT market infrastructures, six entities now hold DLT Pilot authorizations: CSD Prague (DLT SS, 11 Oct 2024), 21X AG (DLT TSS, 3 Dec 2024), 360X AG (DLT MTF, 29 Apr 2025), UAB Axiology DLT (DLT TSS, 9 Jul 2025), LISE SA (DLT TSS, 13 Oct 2025), and Securitize (DLT TSS, CNMV, announced 26 Nov 2025). Source: ESMA — Register of Authorised DLT Market Infrastructures (Jan 2026)
• 5 June 2026 — EU Listing Act prospectus amendments apply. Regulation (EU) 2024/2809 sets a single EUR 12 million prospectus-exemption threshold over 12 months (Member State EUR 5M alternative) and a 30% fungible-securities exemption, relevant to tokenized-securities issuance. Source: Davis Polk — Changes to EU Prospectus Regulation under Listing Act

Related coverage

European Union — License Map in other research domains:

• CBDC Frameworks
• Crypto Mining Regulations
• DeFi Regulation & Liability Frameworks
• Digital Asset Insurance & Risk Transfer
• Digital Asset Taxation
• Institutional Crypto Custody Regulations
• NFT & Digital Collectibles Regulations
• Payment Services & Crypto Payment Regulation
• Stablecoin Regulations & License Regimes
• Tokenized Real-World Assets (RWA) Regulation

Verification Notes

This license-map file was reconciled on 2026-06-04 against the nine refreshed deep-research source-domain files for the European Union (all modified 2026-06-04), per the cross-domain consistency standard. Corrections made during this refresh:

• (a) CASP authorization count. Was "~60--90+", "~102", "~60 as of March 2026"; corrected to ~199-204 authorized CASPs (April-May 2026) to match the crypto-payment-regulation, crypto-mining and stablecoin source files and the ESMA Interim MiCA Register. The "~60" figure was correct as of late 2025 and is retained where dated for historical context elsewhere.
• (b) EMT issuers. Was "19"; corrected to 20 (ESMA register, April 2026; 0 ART issuers).
• (c) DLT Pilot authorizations. Was "3 authorizations (CSD Prague, 21X AG, 360X AG)" and a 5-row key-holders table mis-listing Securitize as a MiFID II investment firm; corrected to 6 authorizations, adding UAB Axiology DLT, LISE SA and Securitize (DLT TSS), per the rwa-regulation source file and ESMA's DLT-infrastructure register.
• (d) Bank consortium. Was "nine-bank euro stablecoin consortium"; corrected to Qivalis (37 banks across 15 countries by 21 May 2026; DNB EMI licensing path) per the stablecoin-regulations source file.
• (e) Prospectus exemption threshold. Was "below EUR 8 million... up to EUR 12 million in some"; corrected to the single EUR 12 million threshold under the EU Listing Act (Regulation (EU) 2024/2809) applicable 5 June 2026, per the rwa-regulation source file.
• (f) PSD3/PSR status. Was "provisionally agreed 27 November 2025... expected in force Q1/Q2 2026"; corrected to COREPER-endorsed final compromise texts (22 April 2026), OJ publication anticipated June/July 2026, per the crypto-payment-regulation source file.
• (g) CASP passport forwarding period — internal inconsistency resolved. One passage said the home NCA forwards within "10 business days"; another (and the payment source) said "5 working days". Corrected to 5 working days (MiCA Article 65), matching the crypto-payment-regulation source file.
• (h) Suspect URL replaced. The DeFi-section source link to esma.europa.eu/press-news/esma-news/mica-implementation could not be confirmed and was replaced with the verified ESMA MiCA activities page plus the Commission's 20 May 2026 MiCA-review consultation URL.

Wikilink convention: Pre-existing cross-domain wikilinks in this file (and across all license-map jurisdiction files) use the bare-domain prefix (e.g. crypto-custody/regulations/...), which is the dominant established convention in this corpus; they were left unchanged. New material added in this refresh introduces no new bare-basename links.

Items not independently re-verified this cycle: the full 37-bank Qivalis roster (no single primary roster located; CaixaBank/BBVA corroborate the headline count); self-reported/estimated cost, capital-stack, staffing-FTE and processing-timeline figures throughout the activity and cost tables (flagged as estimates in-line); banking-onboarding statistics ("14% seamless onboarding", enforcement penalty totals) which carry their original source framing from the underlying domain files.

For Full Details

• EU Custody Regulations -- CASP authorization, asset segregation, strict liability, key management, and institutional custody requirements
• EU Stablecoin Regulations -- EMT/ART authorization, reserve requirements, redemption rights, significant token regime, and interest prohibition
• EU Mining Regulations -- sustainability disclosures, energy permits, PoW ban history, Nordic restrictions, and DAC8 tax reporting
• EU Digital Asset Taxation -- DAC8 reporting, CARF implementation, MiCA-taxation nexus
• EU RWA Regulation -- MiFID II/MiCA classification boundary, DLT Pilot Regime, Prospectus Regulation, ESMA guidelines, institutional tokenization projects
• EU DeFi Regulation -- MiCA CASP framework, Recital 22 exemption, Article 142 review, AMLA, PLD software liability, Tornado Cash
• EU Digital Asset Insurance -- MiCA Article 67 insurance-as-alternative, Solvency II, IDD, passporting, Munich Re, Lloyd's Brussels
• EU Crypto Payment Regulation -- MiCA/PSD2 dual licensing, EMT issuance, PSD3/PSR transition, passporting, stablecoin compliance