MiCA's First 100 Days: Euro Stablecoins Surge as Market Dynamics Shift

One hundred days after the close of the Markets in Crypto-Assets (MiCA) regulation’s transitional period on 1 July 2026, a significant market review has shed light on the profound impact of this regulatory framework on the digital asset ecosystem within the European Union. This multi-contributor report, published by Finery Markets in collaboration with Banking Circle, Fipto, The Vault, and Sumsub, meticulously details how MiCA is actively reshaping digital asset trading, stablecoin issuance, custody practices, and compliance standards across the EU. The insights presented in the review are rigorously supported by an analysis of over 16 million institutional spot crypto trades executed on Finery Markets’ platform during the first nine months of 2026, benchmarked against data from the corresponding period in 2025.

A primary revelation from the market review is the pronounced divergence between institutional Over-The-Counter (OTC) venues and centralized exchanges. Finery Markets observed a substantial 57% year-on-year growth in its OTC spot volume during the nine-month period ending September 2026. This contrasts sharply with a 47% contraction in volume recorded by the top-20 centralized exchanges and a 35% decline across the top-20 decentralized exchanges over the identical timeframe. Furthermore, OTC volume consistently grew each month throughout 2026, while centralized exchange volumes experienced year-on-year declines every month. Sergey Klinkov, managing director at Finery Markets, attributes this notable divergence to structural factors akin to those observed in the evolution of traditional FX markets. He explains that large-block institutional flow naturally gravitates towards OTC rails due to the benefits of execution discretion, minimized market impact, and enhanced capital efficiency. Drawing an analogy to MiFID II, which fostered a consolidation of equities and fixed-income execution within institutional-grade infrastructure as compliance costs pressured smaller brokers, Klinkov anticipates MiCA will induce a similar consolidation within the crypto sector, compelling smaller operators to either merge or exit the market.

Within the segment of non-stablecoin OTC flow, a marked shift in composition was identified. Ethereum’s share of non-stablecoin volume significantly increased from 23% in the first nine months of 2025 to 50% in the same period of 2026, representing a remarkable 222% increase in absolute volume terms. Conversely, Bitcoin’s share diminished from 48% to 29%, accompanied by a 13% decline in its absolute volume.

Stablecoins emerged as a dominant force, accounting for 83% of all trades executed on the Finery Markets platform, with stablecoin volume witnessing a 76% year-on-year surge. Notably, Euro-linked stablecoins represent the fastest-growing sub-segment, albeit from a relatively modest base. EURC volume on the platform experienced an astonishing 46-fold increase year-on-year, though it still constitutes only 0.12% of total stablecoin client flows. On a broader on-chain perspective, the supply of euro-stablecoins reached $848 million by early September 2026, marking a 22.6% increase from $692 million at the start of the year, according to Token Terminal data. In contrast, the supply of dollar-linked stablecoins remained largely flat at approximately $299 billion over the same period. Patrick Mollard, chief executive of Fipto, views this growth in euro-denominated stablecoin supply as a structural shift rather than a direct displacement of dollar liquidity. He highlights that a burgeoning share of demand for euro-denominated stablecoins originates from payment companies in Canada, Africa, and the Asia-Pacific region, who are seeking a regulated euro leg that can be held, redeemed at par, and reconciled under stringent European regulations. Mollard also observed that many firms that failed to meet the 1 July CASP (Crypto-Asset Service Provider) authorization deadline have not exited the market; instead, they have adopted a compliant strategy of partnering with licensed CASPs that bear the regulatory responsibility.

The MiCA regulation also introduces practical burdens for issuers, particularly concerning reserve caps and compliance friction. Ida Mokhtassi, head of legal at Banking Circle, underscores the European Banking Authority’s (EBA) “double test” on reserve concentration as a significant challenge. Under the current rules, a stablecoin issuer holding €1 billion of reserves with smaller credit institutions faces a 5% cap per bank, necessitating at least 20 distinct banking relationships. Furthermore, a 1.5% total-assets test imposes additional constraints. Banking Circle advocates that concentration limits should be calibrated based on the quality of the safeguard rather than merely the size of the bank. Mokhtassi asserts that “Reserves held in a bankruptcy-remote structure are protected whatever the size of the bank holding them,” arguing that the double test should not apply in scenarios where ring-fenced, readily available liquidity directly addresses the EBA’s underlying concern. In terms of compliance operations, Egor Larichkin, legal counsel at Sumsub, notes a nearly 13% quarter-on-quarter drop in EU crypto verifications following the MiCA deadline, with particularly sharp contractions observed in Germany and Belgium. Concurrently, the proportion of EU crypto applicants rejected due to fraud attempts surged by almost half, an increase more than double that seen in other regions. Larichkin attributes this alarming trend to fraudsters exploiting platform re-onboarding processes, specifically targeting users who may be confused by transitions to new legal entities with deceptive re-verification requests.

MiCA’s initial hundred days also sit within a broader EU regulatory landscape, giving rise to important regulatory read-across implications. Artem Stopnevich, chief executive of The Vault, points out that the existing PSD2 framework creates overlapping authorization requirements for e-money token transfers. He emphasizes that a MiCA license alone is insufficient to cover every activity required to operate a comprehensive payment service. The eventual resolution of this regulatory overlap, whether through clearer EBA guidance or targeted legislative refinements during any future PSD3 review, will be crucial in determining how smoothly stablecoin payment rails can integrate with existing payment institution infrastructure. For the present, the commercial incentive clearly favors strategic partnerships over pursuing multiple, parallel licensing efforts.