One hundred days after MiCA’s 1 July registration deadline, the headline number, 280 firms on ESMA‘s initial list, down from 2,747 operating under national transitional regimes in 2024, turns out to be the less consequential data point. According to two reports published by institutional crypto trading infrastructure firm Finery Markets in October 2026, the structural shift playing out underneath the compliance story is about liquidity, not headcount.
EURC, the euro-denominated stablecoin issued by Circle, saw volume on the Finery Markets platform rise 46 times year on year in the first nine months of 2026. Yet it still accounts for just 0.12% of total stablecoin flow through the network. Euro stablecoin supply has grown 22.6% this year to approximately $848 million, while dollar-denominated supply has been flat. The figures confirm MiCA opened a race to build native euro liquidity that remains, as the report puts it, a test of volume rather than availability.
The OTC data behind the first report covers 16 million institutional spot trades across nine months. OTC volume grew 57% year on year while the top 20 centralised exchanges collectively lost 47% of comparable activity. Stablecoins now account for 83% of trades on the network. Contributors include Banking Circle, Fipto, The Vault and identity and compliance firm Sumsub.
The execution layer banks have not built
The second report, focused on bank strategy, finds that 89% of banks have an active budget for digital assets, but only 16% have anything in production. Of the largest institutions surveyed, JPMorgan, Citi, BNY, Morgan Stanley, Bank of America, Standard Chartered, Société Générale, Deutsche Bank, BBVA and Revolut, nearly every live product runs on third-party rails. Custody, tokenised deposits and exchange-traded product access have been delivered. Trading has not.
That gap is the commercial proposition underlying the Finery Markets release. The firm argues that custody addresses a security question, not a revenue one. The client request that follows custody is the ability to trade held assets without routing them to an exchange the bank does not control. Building that internally requires separate bilateral liquidity relationships, each carrying its own credit agreement, fragmented pricing that complicates best-execution obligations, and a settlement infrastructure build measured in quarters rather than weeks.
Finery Markets’ alternative is a non-custodial connection to firm liquidity across more than 200 crypto and fiat pairs, with automated netting, role-based access controls and a full audit trail. Two deployment models are offered: a white-label master account in which the bank remains the regulated counterparty, and a full white-label network in which clients trade with one another and the bank typically avoids the capital requirements of a broker-dealer licence.
Regulatory context and platform updates
The regulatory read-across is substantial. In the US, the OCC has granted 16 digital asset trust charters in ten months. The GENIUS Act, MiCA, the UK’s evolving digital assets regime and Basel III capital treatment of crypto exposures are all shaping what banks can offer and at what cost. Roughly one fifth of the current MiCA register is now composed of banks, which reflects an appetite but also a compliance overhead that smaller specialist CASPs have been faster to absorb.
Finery Markets also disclosed two platform updates this month. The connectivity hub now allows institutional participants to store exchange API credentials directly within the platform interface, integrating price discovery from venues covering what the firm describes as more than two thirds of global crypto liquidity. The white-label stack has been updated with embedded API documentation, which the company says has reduced client integration timelines by a factor of 18.7 compared with a prior baseline, a figure it attributes to an AI-assisted integration repository. The 18.7 multiplier is not independently benchmarked in the release.
The firm also co-hosted a private luncheon at TOKEN2049 Singapore with Caladan, Utila and Stablecoin Insider, drawing approximately 150 professionals from OTC trading, market making, payments and stablecoin infrastructure. The consensus from those conversations, as reported by Finery Markets, was that firms growing fastest are treating routing, settlement and prefunding as infrastructure decisions rather than operational workarounds.
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