Konstantins Vasilenko is Co-Founder and CBDO at Paybis, a crypto platform licensed in Latvia. He has more than 20 years of experience spanning enterprise IT project management, CRM systems, blockchain technology, digital payments and cryptocurrencies. In this contributed opinion piece, he argues that the licence table is the wrong measure of where Europe’s crypto infrastructure is being built.

Europe has started treating its MiCA authorisation register as a league table. In the latest September snapshot, Germany leads with 89 authorised crypto-asset service providers, ahead of France with 35 and the Netherlands with 29. Across the Baltics, Lithuania has 13, Latvia 10 and Estonia three.

Germany is clearly ahead if the question is where permissions have accumulated. But the licence table is the wrong measure for where Europe’s next layer of crypto infrastructure is being built.

A MiCA authorisation says little about the infrastructure a firm has behind it. A bank adding crypto custody and a crypto company connecting digital assets to payment and settlement systems can each occupy one line in the same register.

The table is useful for counting authorisations. It tells us much less about operating capacity. To see where crypto firms are gaining the infrastructure to move money and serve customers across Europe, licence totals are not enough.

MiCA has weakened the link between a company’s home jurisdiction and the market it can serve. Once authorised in one member state, a CASP can use the EU’s cross-border notification framework to operate elsewhere in Europe. The largest domestic financial market does not automatically make the best base for a cross-border crypto business.

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