After One Year of MiCA, Where Is Enforcement Actually At in 2026?

MiCA entered full force on 30 December 2024, and seventeen months later the question is no longer what the text says but what enforcement actually does. How many CASP licences have been issued? Did stablecoins really get delisted? This piece uses 2025 full-year and 2026 H1 data to align MiCA’s written rules with what has actually happened. For the legislative structure itself see What Is MiCA? The EU’s Crypto Regulation Framework Explained; this article will not repeat that ground.

The Real Pace of CASP Licensing

The Crypto-Asset Service Provider licence under MiCA Title V is the central compliance tool covering exchanges, custodians, market makers and advisory firms. Alongside full effect on 30 December 2024 the EU granted an eighteen-month transitional window: any provider already registered under national rules could continue to operate but had to obtain a proper CASP licence by 30 June 2026 or wind down. That makes the first half of 2026 the final sprint of the transition.

As of May 2026, the public ESMA CASP register shows just under sixty fully approved CASP licences. The most active competent authorities are in Malta, Ireland, Luxembourg, France and Germany, which together account for around sixty percent of approvals.

Landmark decisions: Coinbase picked Luxembourg as its EU lead jurisdiction in June 2025; Kraken took the Irish route in September 2025; Binance, after dense 2024 remediation, secured CASP licences from Malta and France in late 2025; OKX completed French licensing in Q4 2025. None chose their original home base; the picks reflect supervisory dialogue, taxation, hiring and EU-passport value.

The Stablecoin Reshuffle: USDC Versus USDT

MiCA’s stablecoin chapters under Titles III and IV took effect on 30 June 2024, six months ahead of the rest of the regulation. That early window gave EU-licensed venues time to clear their order books, and the results are now plainly visible on the tape.

By May 2026, EUR/USDT spot pairs have essentially vanished from EU-licensed exchanges. Kraken, Bitstamp and Coinbase delisted the pair in waves during the second half of 2024. Binance finished its delisting in Q2 2025 with a short sell-only window and closed it by year-end. Tether has neither applied for nor obtained an EMI licence; its public position is that MiCA’s reserve constraints (no commercial paper, mandatory EU-bank reserve portion) would hurt commercial flexibility.

The mirror case is Circle’s USDC. Circle obtained an EMI licence from the French ACPR in July 2024, becoming one of the first compliant EMT issuers under MiCA. Seventeen months later, USDC’s share of EU-venue stablecoin volume has grown from under fifteen percent in early 2024 to roughly sixty percent in Q1 2026. Native euro stablecoins are also taking shape: Société Générale-Forge’s EURCV, Circle’s EURC, and Banking Circle’s EUROP all hold EMT status, and on-chain euro liquidity has gone from non-existent to a small but functioning market. The detailed contrast is laid out in USDC vs USDT Compared.

ESMA Guidance and Enforcement Cases

Between 2025 and the first half of 2026, ESMA published several pieces of secondary legislation and guidance:

1. RTS on CASP own funds, in force from March 2025, fixing minimum capital and liquid-asset ratios for exchanges and custodians
2. Client-asset segregation detailed rules, June 2025, requiring all licensed CASPs to complete on-chain and bank-account segregation audits within twelve months
3. Market abuse monitoring guidelines (MAR for crypto), November 2025, requiring CASPs to feed suspicious-activity reports into a central ESMA database
4. DeFi front-end liability consultation paper, draft published February 2026 with public feedback closing in June — the most debated piece of secondary work this past year

On enforcement, EU member states collectively issued twenty-three formal crypto-related supervisory sanctions across 2025, roughly five times the 2023 number. Two cases drew most attention: Italy’s Consob fined a small unlicensed exchange 2.8 million euros, and Germany’s BaFin issued a remediation order plus a ninety-day new-business suspension on a custodian that had failed asset-segregation requirements. The pattern is “not particularly large, but dense” — unlike the occasional billion-dollar US SEC action, MiCA prefers low-amount, high-frequency, clearly predictable enforcement.

Where the Unlicensed Smaller Venues Went

Not every venue previously operating in the EU could or wanted to enter the MiCA system. By May 2026, at least fourteen mid-sized and smaller exchanges previously registered in some EU member state have actively exited the EU market. They share a common profile: under one hundred thousand users, no dedicated compliance team, and EU revenue making up a minor share. The exit pattern is two steps:

• Step one: close new sign-ups and end EU fiat on-ramps
• Step two: give existing EU users a ninety-day withdrawal window, then close accounts

MiCA’s passporting effect has flipped into a clearing effect — failing to get one licence now means losing access to all twenty-seven member states at once. For the broader exchange landscape see Top Global Exchanges Compared.

The DeFi Grey Zone: Defining “Fully Decentralised”

The MiCA text carries a much-quoted exemption: protocols that are “fully decentralised” sit outside CASP supervision. But the text never defined the test, leaving the work to secondary legislation and case law. Through 2025 and into 2026 ESMA and national supervisors have made their stance clearer: the protocol code may be decentralised, but if the front end, domain, operating company or governance multisig has identifiable persons behind it, that layer can be deemed a CASP.

A signal case came in November 2025 when France’s AMF told a French-registered DEX aggregator front end to register as a CASP, citing the front-end company’s clear legal representative and team-held multisig keys. The working definition emerging from cases puts four boxes on a checklist: no identifiable operating entity, no team-controlled upgrade keys, no front-end company, and no active marketing to EU users. Few protocols meet all four. Ongoing tracking is best read alongside the regulation news roundup.

Four Rulers for MiCA’s Real Progress

Putting the facts together, four rulers measure MiCA’s progress in mid-2026:

• Legislative completion: about 95 percent. Primary text in force, most RTS and ITS published
• Licensing completion: about 70 percent. Top venues licensed, more approvals before the June deadline
• Enforcement completion: about 50 percent. Fines and remediation orders flowing, market abuse data just connected
• DeFi governance completion: about 20 percent. Front-end liability and decentralisation tests still in consultation

That spread explains the polarised market view. Already-compliant players see unprecedented predictability; players who were swept off see effective market closure. A real verdict on MiCA will require the transitional period to expire in late June 2026, the first revocation cases to surface, and the DeFi front-end rules to be finalised. Until then, each month is another calibration cycle for an EU-scale regulatory experiment.