Germany fills the MiCA register. But a company needs the specific authorisation

Germany has the most crypto-asset service provider records in the currently available European MiCA register file. But when we open the data rather than the headline, a more important story emerges: one table contains banks, specialist companies, repeated identifiers and records with expired or future authorisation dates. The number of rows therefore does not represent the number of separate licences currently valid.

For a Czech or Slovak company, this distinction is not academic. What matters is whether it contracts with an authorised entity, whether that entity’s scope covers the service ordered and whether it may provide it in the relevant country. The European register provides the necessary pointers for this check. It must, however, be read as a legal record, not a popularity ranking.

Summary for readers

• The downloaded CASPS file contains 346 data records and 342 distinct LEI identifiers. Germany accounts for 89 rows. These figures do not count active licences or customers.
• MiCA distinguishes a new provider authorisation from notification by certain already regulated financial institutions. The register captures both routes; a bank does not need the same new authorisation as a standalone crypto company for every entry.
• Verification concerns a specific legal entity, service, territory and date. One company’s authorisation does not automatically protect a contract with another member of its group.

1. What recounting the register actually showed

ESMA states that the overview was last updated on 9 September 2026. Our recount of CASPS.csv, downloaded on 11 September, found 346 data rows. By the home state field, 89 belong to Germany, 35 to France and 29 to the Netherlands. Defined in this way, the figure confirms Germany’s lead in the number of records in that snapshot.

The same file, however, contains only 342 distinct LEIs. Three identifiers recur among German records. Across the file, two termination dates are populated and one record has a start date in October 2026. A future date is not necessarily an error; it cannot, however, be counted as an authorisation already effective during September research.

We therefore do not publish a derived number of “active licences”. That would require resolving all identity and timing differences and distinguishing the legal basis of registration. An accurate record count is more useful than an apparently precise but incorrectly labelled number of authorisations.

2. Bank notification and new authorisation are two routes

For a standalone provider, MiCA envisages an authorisation procedure. For certain already regulated financial institutions, however, it uses a different process. Article 60 permits specified services after notification to the home authority, accompanied by prescribed information. For a credit institution, for example, this means notification at least forty working days before first providing services.

This route does not mean operating without supervision. It builds on an existing financial authorisation and requires information on intended services, risk management, systems or protection of customer funds. The scope is not the same for all types of financial institutions. A bank, investment firm and electronic money institution are therefore not interchangeable categories.

The increase in bank names in the German records can be interpreted as an expansion of the distribution base. The table alone does not tell us how many of these institutions already have active customers, what volumes they process or whether they operate common technology. Attributing the same commercial weight to every row would confuse legal readiness with actual service use.

3. The home state does not say whom a service is available to

A business seeking a partner need not restrict its choice to providers based in Czechia or Slovakia. The European regime permits cross-border provision, but works with specific services and countries. Article 65 of MiCA requires notification of the list of target states, services and planned start. It also governs transmission of information and the point at which provision may begin.

In the ESMA file, the field identifying territories where services are provided is therefore relevant alongside the home country. Having Germany as the home state is not synonymous with permission for any activity everywhere in Europe. Nor does a website being available in Czech establish that the particular service offered covers the Czech Republic.

The practical process starts with the contract: compare the company’s exact name and identifier with the register, then check the required activity and territory. Several companies often share one brand. The actual partner may differ by product or customer location, and this detail is decisive when making a complaint or requesting the return of assets.

4. The end of the transitional period was not a deadline merely to apply

Media shorthand sometimes suggests that applying for authorisation by 1 July 2026 was enough. In its statement of 23 June, ESMA explained the end of transitional periods and the requirement to cease unauthorised activity. Submitting an application does not itself create a right to continue serving customers after the transitional regime ends.

The Czech National Bank also explicitly distinguishes authorised providers from duly notified banks and other financial institutions. It stresses verifying authorisation during an ongoing contractual relationship too. An old trade registration or an announcement that “we are in the licensing process” is therefore insufficient as current operational evidence for a company.

When the contracting entity changes, it is necessary to check where assets are moving, who retains previous obligations and whether the customer has actually completed new onboarding. Redirecting a website to a European domain does not itself explain transfer of the legal relationship. A company should retain a record of consent, when the change takes effect and any transfer of balances.

5. A money issuer and a service provider are not the same

Alongside providers, the MiCA register includes information on tokens and issuers. This produces another common statistical error: individual rows are presented as new companies. The EMTWP.csv we downloaded contains 47 rows but only 24 distinct LEIs. One issuer may appear repeatedly for different tokens or documents. The number of these rows is therefore not a count of new issuer licences either.

An electronic money token, or EMT, references a single official currency. An asset-referenced token, or ART, tracks a different composition of references within its legal definition. CASP denotes the provider of a particular service, such as custody or exchange. These terms describe different parts of a transaction.

A company may buy an EMT through one provider, hold it with another and exercise redemption against the issuer. Selecting a regulated intermediary does not eliminate the need to examine the token and its legal debtor. This is where a useful responsibility map emerges: issuance, trading, custody and payment of money separately. A single logo on the user’s screen does not replace this map.

6. A service licence is not investment approval

For tokenising corporate financing, it is especially important not to use MiCA as a universal label. In its statement of 21 August 2026, the Czech National Bank analyses assessment of a token with a right to a distribution on liquidation. The legal substance of the claim is decisive; the technology alone does not determine whether it is a financial instrument, a crypto-asset under MiCA or a differently regulated structure.

A business therefore cannot infer that every entity in the CASP register may distribute its planned tokenised investment. The instrument itself must first be classified. Only then can it be checked whether the selected partner has the authorisation needed for the specific activity involving that instrument.

The Czech National Bank also notes that for most crypto-assets, the white paper’s contents are not subject to approval and supervision does not assess the project’s returns. A reference to registered documentation therefore does not confirm economic quality. For a corporate decision, analysing the business model, the issuer’s financial capacity and the enforceability of promised rights remain separate tasks.

7. What Czech and Slovak customers might gain from German growth

The entry of more banks may eventually improve service availability through familiar distribution channels. This is a reasonable possibility, not an outcome proven by the number of records. The official table does not reveal prices, availability of corporate accounts, support for Czech crowns or the quality of customer service.

For a Slovak customer, the NBS register of entities is a useful complement, separating categories by authorisation and territorial scope. Different totals in national and European overviews need not mean a contradiction: they may reflect a different selection, legal basis or update date.

A comparison of offerings should therefore have two parts. First, demonstrable authorisation and legal responsibility; then operational suitability. The second part covers receiving and withdrawing money, supported networks, limits, handling corporate signatures and exporting documentation for accounting. Without it, a regulated service may remain practically unusable for a specific business even though the provider is correctly listed in the register.

8. Verification should end with retained evidence

A good check does not end with “we found the company at ESMA”, but with a short dated record. It should connect the contracting company, LEI, relevant supervisor, legal basis, list of services, target countries and period of validity. If something does not match, the supplier’s answer should be checked against the relevant authority; vague marketing language is no substitute.

It is also worth recording who in the company checked the authorisation and which event triggers another review. Practical triggers include a change in the contracting entity, expansion of the service ordered or a move of custody. A downloaded snapshot preserves what was available at the decision time; it does not prove an unchanging future status.

Imagine, for example, a provider whose entry covers exchange and execution of orders, while its customer offering also promises long-term custody. This is a hypothetical example, not a finding concerning a specific company. The correct response is to identify the entity responsible for custody and verify its own scope. A contract may legitimately involve another regulated partner, but the customer must know which one. The same check applies if an original exchange service expands to portfolio management. An additional product cannot be approved merely because the first service once passed review. This approach gives the control record practical significance even after cooperation begins.

Germany’s lead in the current row count is a real and interesting signal. A suitable partner for a domestic company, however, will only be determined by combining a specific authorisation, a specific contract and verified operations. European regulation gives this decision a structure. Corporate responsibility consists in applying it beyond the headline about licence numbers.

Links and sources

CoinGeek — Germany leads MiCA licenses as EU tightens crypto rules

ESMA — MiCA and methodology of the interim register; stated update 9. 9. 2026

ESMA — CASPS.csv, source file downloaded 11. 9. 2026

ESMA — EMTWP.csv, source file downloaded 11. 9. 2026

ESMA Single Rulebook — Article 60, services provided by certain financial institutions

ESMA Single Rulebook — Article 65, cross-border provision of services

ESMA — MiCA transitional period ends, statement of 23. 6. 2026

ČNB — notice on the end of the MiCA transitional period as of 1. 7. 2026

NBS — crypto-asset market entities, categorised by authorisation and territorial scope

ČNB — RS2026-11, assessment of a crypto-asset with a right to a distribution on liquidation, 21. 8. 2026

Methodological note

The status of sources was verified on 11 September 2026. The official CASPS.csv and EMTWP.csv files were physically downloaded and archived with SHA-256 checksums. Rows were counted using a CSV parser, not by counting text lines; records may contain line breaks. LEI counts eliminate repeated identifiers but do not by themselves resolve all historical changes in names or legal bases. The figures 346, 89 and 47 are gross record counts in the snapshot, including entries that are not current in time. They are not a total of effective licences. The register also covers EEA states outside the EU; without filtering, the file cannot be described as statistics solely for the EU’s 27 countries. The CSV changes continuously at the same URL, and ESMA warns of a delay between national records and its own update.

Basis of the article: our own examination of ESMA data files downloaded on 11. 9. 2026, explanation of the difference between authorisation and notification by a financial institution, and primary statements by European, Czech and Slovak authorities. The media lead is a CoinGeek article on Germany’s licence count. We do not adopt its August total as current statistics.

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This article is for information and educational purposes. It does not constitute legal, investment, tax or regulatory advice and is not a recommendation of any particular provider or token. Authorisation must be checked for the specific entity, service, territory and current date; regulatory registration does not guarantee returns or a risk-free service.