MiCA Mania: Germany Takes Regulatory Helm as Baltics Build EU's Crypto Future

More than a year after the implementation of the EU’s Markets in Crypto-Assets (MiCA) regime, the conventional method of gauging member state success through the number of authorised crypto-asset service providers (CASPs) has proven to be a misleading indicator. While Germany comfortably leads the count with 89 authorised CASPs, followed by France with 35 and the Netherlands with 29, this simple licence table fails to reflect where Europe's next layer of crypto infrastructure is genuinely being developed. Konstantins Vasilenko, Co-Founder and CBDO at Paybis, a crypto platform licensed in Latvia, argues that a MiCA authorisation alone says little about a firm's underlying operational capacity or its ability to connect digital assets to crucial payment and settlement systems.

The MiCA framework has significantly altered the relationship between a company's home jurisdiction and its market reach. Once authorised in a single member state, a CASP can leverage the EU’s cross-border notification system to operate across the entire European Union. This means that a large domestic financial market no longer automatically equates to the optimal base for a burgeoning cross-border crypto business.

The Baltic states offer compelling evidence for why raw licence totals can be deceptive. Estonia, for instance, saw its count of licensed virtual-asset firms plummet from 1,234 at the end of 2019 to just 53 by December 2023, following stricter regulatory enforcement. This dramatic reduction illustrates how quickly a seemingly impressive licence tally can lose its significance once rigorous supervision is applied. Conversely, Lithuania presents a different narrative, boasting 248 fintech companies that serve nearly 40 million customers across Europe, employing over 7,800 individuals in the sector. In 2025, its payment and electronic-money institutions processed a staggering €166 billion in payments. Crypto companies entering this market benefit from building alongside an already established payments industry, complete with experienced teams and scalable systems for regulated money movement.

Latvia, in particular, highlights a strategic approach to infrastructure development. Four of its first ten MiCA-authorised CASPs, including Paybis, Nexdesk, Nodu Digital, and Trek Technologies, also hold payment-institution permissions. Many of these firms received both their MiCA and payment licences concurrently, often within a short timeframe. These 'paired licences' are critical as they cover different facets of a single transaction, enabling customers to move euros, facilitating business settlement, and providing platforms with direct access to payment systems in addition to permission for digital asset handling. Latvijas Banka actively supports this integration, charging a modest €2,500 for CASP authorisation applications – one of the lowest fees in the EU – and offering unlimited free consultations, including during the pre-legal establishment phase. Its pre-licensing process allows firms to test business plans and documentation with supervisors before formal submission, providing invaluable early regulatory feedback. Furthermore, eligible non-bank payment and electronic-money institutions can directly access Latvijas Banka’s EKS payment system for euro payments across the SEPA zone.

While transaction volume has not yet decisively shifted from larger markets to the Baltics, the foundational 'build-out' required to compete for such volume is already evident. A firm needs regulatory permission, payment access, banking connections, products, and distribution before significant transaction volume materialises. Germany’s strength lies in its large banks and financial institutions integrating digital assets into mainstream finance. However, in the Baltics, firms are strategically combining crypto authorisation with essential payment infrastructure, effectively constructing the rails needed to connect digital assets to the broader financial ecosystem. Therefore, while the license table may point to Germany as the leader in sheer numbers, Europe’s crucial crypto infrastructure is increasingly being forged in the Baltics.