The Markets in Crypto Assets Regulation (MiCA) officially came into force on December 31, 2024, marking a new era for Crypto Asset Service Providers (CASPs) — also commonly known as Virtual Asset Service Providers (VASPs) — across the European Union. In the first three months of 2025, we’ve seen the early signs of how the regulatory landscape is shifting — and which jurisdictions are beginning to emerge as authorization hubs.
According to the European Securities and Markets Authority (ESMA) register, as of April 15, 2025, 17 CASPs have received authorization under MiCA across seven EU member states. Alongside this register, ESMA maintains a list of non-compliant entities — those operating without appropriate authorization. As of the same date, 15 entities are included on this list, all reported by Commissione Nazionale per le Società e la Borsa (CONSOB) in Italy.
But is this the full picture of CASP activity in Europe?
How MiCA shifted the landscape from fragmentation to harmonization
Prior to MiCA, the regulatory landscape for CASPs was highly fragmented. Over 3,000 CASP registrations or licenses had been issued across the EU, but they varied significantly in scope and substance. And while some jurisdictions permitted individuals to register as CASPs, others required firms to demonstrate substantive virtual asset activity.
At TRM Labs, we estimate that the true number of operational CASPs in the EU before MiCA’s implementation was likely in the range of 1,100 – 1,300. This estimate is based on our proprietary methodology for assessing the operational footprint and location of CASPs across the bloc.
MiCA aims to replace this patchwork with a single, harmonized rulebook. All CASPs seeking to operate in the EU must now go through a standardized authorization process — raising the bar for compliance and clarity.
What happens to the 3,000+ pre-MiCA registrations?
According to the current ESMA registers, only 32 CASPs are now formally recognized at the pan-European level — split evenly between the authorized and non-compliant lists. Taking our previous estimate of over 1,000 CASPs in Europe pre-MiCA coming into force, that leaves the vast majority of these requiring authorization over the next 15 months.
It’s important to note that timelines for compliance vary. CASPs previously operating under national regimes benefit from grandfathering provisions, with deadlines dependent on the transitional arrangements of their respective member states. However, any new market entrants post-December 31, 2024 must obtain full authorization before beginning their operations.
What to expect in the months ahead
Over the next 15 months, TRM Labs will closely monitor the progression of MiCA authorizations. We will be tracking where CASPs are choosing to set up shop, as well as where member states are successfully positioning themselves as regulatory and commercial hubs for crypto activity.
The bottom line is that not all CASPs will make the transition. Some may exit the market, merge with others, or relocate outside the EU. As a result, we anticipate a net contraction in the number of CASPs operating under MiCA, even as the regime enhances regulatory certainty and consumer protection.
It’s too early to call which countries will emerge as the leading destinations for authorization — or whether certain categories of CASPs (e.g. trading platforms vs. custodians) will gravitate toward specific jurisdictions. What is clear is that MiCA is already reshaping the regulatory map of Europe, and this first quarter offers a valuable glimpse into what lies ahead.
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