More than a year into the EU’s Markets in Crypto-Assets regime, the register of authorised crypto-asset service providers (CASPs) has become a shorthand for which member states are winning. On a count of licences, Germany is comfortably ahead.
Konstantins Vasilenko is Co-Founder and CBDO at Paybis, a crypto platform licensed in Latvia. He has more than 20 years of experience spanning enterprise IT project management, CRM systems, blockchain technology, digital payments and cryptocurrencies. In this contributed opinion piece, he argues that the licence table is the wrong measure of where Europe’s crypto infrastructure is being built.
Europe has started treating its MiCA authorisation register as a league table. In the latest September snapshot, Germany leads with 89 authorised crypto-asset service providers, ahead of France with 35 and the Netherlands with 29. Across the Baltics, Lithuania has 13, Latvia 10 and Estonia three.
Germany is clearly ahead if the question is where permissions have accumulated. But the licence table is the wrong measure for where Europe’s next layer of crypto infrastructure is being built.
A MiCA authorisation says little about the infrastructure a firm has behind it. A bank adding crypto custody and a crypto company connecting digital assets to payment and settlement systems can each occupy one line in the same register.
The table is useful for counting authorisations. It tells us much less about operating capacity. To see where crypto firms are gaining the infrastructure to move money and serve customers across Europe, licence totals are not enough.
MiCA changed what location means
MiCA has weakened the link between a company’s home jurisdiction and the market it can serve. Once authorised in one member state, a CASP can use the EU’s cross-border notification framework to operate elsewhere in Europe. The largest domestic financial market does not automatically make the best base for a cross-border crypto business.
The Baltics know better than most why licence totals can mislead. Take Estonia, for example. At the end of 2019, it had 1,234 licensed virtual-asset firms. By December 2023, after the rules tightened, that number had fallen to just 53. Estonia’s experience shows how quickly a large licence count can lose its meaning once supervision becomes stricter.
Lithuania’s story is very different. It has 248 fintech companies serving nearly 40 million customers across Europe. More than 7,800 people work in the sector. Its payment and electronic-money institutions processed €166 billion in payments in 2025. Crypto companies entering that market are building beside an established payments industry with experienced teams and systems already moving regulated money at scale.
Count what the licence lets a firm build
The Latvian register shows that four of the country’s first 10 MiCA-authorised CASPs also hold payment-institution permissions: Paybis, Nexdesk, Nodu Digital and Trek Technologies.
Paybis received its MiCA and payment licences together in May 2026. Later that month, Nexdesk added a payment-institution licence to the MiCA authorisation it had received in December 2025. Trek Technologies received both authorisations in May 2026 and Nodu Digital followed with both licences in July 2026. Four Latvian firms now hold both MiCA and payment-institution permissions. Three of them, Paybis, Trek and Nodu, received both licences at the same time, all within less than two months.
Those paired licences cover different parts of the same transaction. Customers need to move euros in and out. Businesses need settlement. Platforms need access to payment systems as well as permission to handle digital assets.
Latvia has tried to make both the regulatory and payments sides of that process more predictable. Latvijas Banka charges €2,500 to review a CASP authorisation application, one of the lowest application fees in the EU. It also offers applicants unlimited free consultations, including before the company is legally established. Its pre-licensing process lets firms test business plans and documentation with supervisors before making a formal filing.
Latvia’s advantage here is earlier regulatory feedback. Firms can find out what regulators expect and what they will have to change before filing formally. Eligible non-bank payment and electronic-money institutions can also access Latvijas Banka’s EKS payment system directly for euro payments across SEPA.
Volume comes later
The obvious objection is transaction volume. If the Baltics are becoming an infrastructure centre, why has usage not already shifted decisively away from larger markets?
A firm first needs regulatory permission, payment access, banking connections, products and distribution. Transaction volume only starts to show the result once those pieces are in place.
There is not yet enough post-MiCA operating history to claim that Latvia or the wider Baltics have overtaken Germany on crypto volume. But the build-out needed to compete for that volume is already visible.
Germany’s large banks and financial institutions entering crypto show that digital assets are moving deeper into mainstream finance. In the Baltics, firms are combining crypto authorisation with the payment infrastructure needed to connect digital assets to the rest of the financial system.
Germany is winning a different contest
Germany will remain a far larger financial market than Latvia, Lithuania or Estonia. But MiCA makes domestic market size less decisive when a company can establish itself in one jurisdiction and serve customers across the EU.
If that base also gives it access to the payment system, a small market can carry much more weight than its size suggests. So, yes, the licence table points to Germany. However, Europe’s crypto rails are increasingly being built in the Baltics.
The post Germany Leads the MiCA Register, But the Baltics Build the Rails appeared first on The Fintech Times.
