The EU Markets in Crypto-Assets (MiCA) regulation came into full effect on 1 January 2025. This means that compliance with the MiCA regulation has been a reality for EU crypto-asset service providers (CASPs) for the last 6 months and for stablecoin issuers (ARTs and EMTs) for the last 12 months.
In our last post we analysed the core pieces of the EU-wide legislation and discussed its potential impact on the insurance industry. As execution of MiCA gains steam, it’s instructive to see the progress of MiCA adoption across the EU.
The following statistics are drawn from the European Securities and Markets Authority’s Interim MiCA Register update on 22 July 2025.
EMTs
Electronic Money Tokens (EMTs) are regulated by Title IV of MiCA and the regulation has been in effect since June 2024.
In short, EMTs are crypto tokens pegged to a single fiat currency and MiCA regulation requires that EMT issuers hold one unit of fiat currency (or equivalent liquid assets) for every issued token.
As of 22 July 2025, 12 different firms from 7 member states have been approved by their respective financial regulators as EMTs under MiCA.
Across these 12 entities, 21 stablecoins pegged to the euro, US dollar and Cech koruna have been approved, with one company being authorised to issue a stablecoin pegged to an as-yet-unknown fiat currency.
ARTs
Asset-Referenced Tokens (ARTs) are regulated by Title III of MiCA which, like Title IV, has been in effect since June 2024.
The distinguishing factor between ARTs and EMTs relates to the asset each is referencing; while EMTs are pegged to a single fiat currency, thereby mimicking fiat money, ARTs are pegged to a basket of assets, which could be fiat currencies, cryptocurrencies, commodities, etc.
As of 11 July 2025, no ARTs have been approved under MiCA, reflecting, on one hand, the strict regulatory requirements ART issuers are subject to and, on the other, the limited demand, infrastructure and concrete use cases for multi-asset tokens in the EU.
CASPs
Crypto-Asset Service Providers (CASPs), which are regulated by Title V of MiCA, have been subject to MiCA regulation since 31 December 2024.
Essentially, the MiCA regulation states that “any person whose occupation or business is the provision of one or more crypto-asset services to third parties on a professional basis” is classified as a CASP. Provision of crypto-asset services can be construed as anything ranging from custody and administration of crypto-assets to placement of crypto-assets or the operation of a crypto-asset trading platform. For a more complete definition, please consult our MiCA guide.
As of the latest ESMA Interim MiCA Register update, 46 entities have been authorised to operate as CASPs under the MiCA regulation from 11 different EU Member States.
It should be noted that Germany and the Netherlands are clearly leading the way in terms of MiCA regulation CASP adoption, representing over half of the approved CASPs so far.
These 46 separate entities are split between crypto-native, fintech and traditional finance players, with a higher percentage falling under the former’s classification in accordance with the types of crypto-asset services provided.
Conclusion
Six months on, MiCA adoption is already running at full steam in some EU Member States while others appear to still be in a coordination stage with their respective local authorities. Regardless, with over 180 whitepapers from 13 different member states submitted for review, MiCA is now a reality in the EU cryptosphere and the race for compliance is on.
Prudential requirements that MiCA authorisation is subject to across the EU mandates that issuers and CASPs must maintain minimum capital requirements of:
- €150k if classified as trading platforms
- €125k if classified as custodians and/or exchanges
- €50k if classified as any other form of CASP
Alternatively, firms may opt for an insurance policy that covers professional negligence liabilities. This frees up the capital EU crypto players would be required to lock away and is a safe, simple and practical alternative to MiCA prudential obligations while maintaining the focus on compliance.
At Elmore, we focus on helping crypto firms guarantee compliance through our MiCA-specific insurance solutions that protect your business and your stakeholders.
Contact us today to discuss your MiCA insurance strategy and download our comprehensive MiCA Insurance Guide.