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EU MiCA Officially Takes Effect: A Guide to the CASP Authorization System and Compliance Landscape of Major Trading Platforms

黑色马里奥
特邀专栏作者
2026-07-07 06:20
This article is about 9695 words, reading the full article takes about 14 minutes
How exactly is MiCA’s CASP authorization categorized, and what are the differences in regulatory requirements faced by various platforms?
AI Summary
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  • Core Insight: The European Union’s Markets in Crypto-Assets Regulation (MiCA) ended its transitional period on July 1, 2025. Trading platforms that have not obtained Crypto-Asset Service Provider (CASP) authorization will be prohibited from offering services to EU users. CASP is not a single license but an authorization system based on service codes (a to j) and minimum capital requirements (Class 1-3). Currently, only 18 entities have obtained Class 3 authorization, which includes the operation of a trading platform (category b). Major platforms like Coinbase and Bybit are mostly concentrated in Class 2, while leading platforms like Binance have not yet clearly obtained authorization.
  • Key Elements:
    1. The core of MiCA is to establish a unified regulatory framework for crypto assets across the 27 EU member states, covering the issuance of stablecoins and the provision of crypto-asset services. In principle, platforms without CASP authorization will be unable to operate in the EU after the transition period ends.
    2. CASP authorization is subdivided into 10 service codes, from a (custody) to j (transfer). Class 1 (€50,000 minimum capital) covers lighter services such as brokerage and advisory. Class 2 (€125,000 minimum capital) adds custody and exchange services. Class 3 (€150,000 minimum capital) includes the operation of a trading platform (category b) and represents the most comprehensive authorization.
    3. As of July 2026, there were a total of 279 authorized CASP entities, but only 18 had obtained Class 3 authorization with category b services. These include OKX, Kraken, Bitstamp, and Bitvavo, among others, though the specific range of authorized service codes varies by platform.
    4. Major platforms like Coinbase, Bybit, Crypto.com, KuCoin, and Robinhood Europe currently hold Class 2 authorization, covering services such as custody, exchange, and transfers, but not the operation of a trading platform (category b).
    5. Global major platforms such as Binance, Bitget, MEXC, and HTX do not currently appear in the ESMA CASP authorization table as having obtained MiCA authorization. This may lead to pressure to reduce operations, migrate users, or exit the EU market.

EU MiCA Officially Takes Effect: A Deep Dive into the CASP Authorization Framework and Compliance Landscape of Major Trading Platforms

As of July 1st this year, the CASP transitional period under the MiCA regulation has officially ended. This means that, in principle, any crypto-asset trading platform that has not obtained a CASP authorization will no longer be able to continue providing services to users within the European Union.

For the entire industry, this day marks a clear watershed.

The situation is mixed: Some major platforms have already secured their licenses and smoothly entered the MiCA regulatory framework. However, many others have yet to make substantial progress and may now face pressure to shrink operations, witness user migration, or even gradually exit the EU market.

In fact, the MiCA regulatory framework for Crypto-Asset Service Providers had already become applicable by the end of 2024. During the past year or so, the market was largely digesting the rules, applying for licenses, and adjusting business structures within the transitional period. With the transition now over, MiCA has truly entered its enforcement phase.

Of course, many people still lack a clear understanding of how the MiCA CASP authorizations are categorized, the differences in regulatory requirements faced by various platforms, and the practical impact this will have on exchanges and EU users.

Markets in Crypto-Assets Regulation

MiCA is a unified regulatory framework established by the EU for the crypto-asset market. Its full name is Markets in Crypto-Assets Regulation.

Its core purpose is to create a set of commonly applicable rules for crypto-assets across the 27 EU member states, covering the issuance, trading, custody, exchange, order execution, transfer of crypto-assets, and related service provisions, including for stablecoins. This aims to unify the previously fragmented crypto regulatory landscape across member states, requiring issuers and service providers to operate under clear requirements for licensing, capital, governance, risk management, information disclosure, and client asset protection.

Focusing on the MiCA framework itself, it primarily targets two main categories of entities:

The first category is **issuers of crypto-assets**, especially issuers of Asset-Referenced Tokens (ARTs) and E-Money Tokens (EMTs).

These entities need to obtain the relevant issuer authorization, disclose a white paper according to regulatory requirements, establish reserve arrangements, and meet ongoing compliance requirements related to governance and risk management.

For the market, ARTs and EMTs are the two most critical objects of MiCA's issuance-side regulation. ARTs are more akin to stablecoins pegged to a basket of assets, while EMTs primarily correspond to stablecoins pegged to a single fiat currency, such as USDC.

However, issuance-side regulation is not the focus of this article. We can dedicate a separate piece to discuss this part in detail later.

The second category is **Crypto-Asset Service Providers**, or CASPs for short.

This category mainly includes crypto exchanges, custodians, brokers, order executors, and crypto-asset transfer service providers. Unlike the issuer system, CASP regulation focuses on how platforms provide crypto-asset related services to clients, including trading, custody, exchange, order execution, investment advice, portfolio management, and asset transfers.

Accordingly, MiCA's regulatory requirements for CASPs are primarily concentrated on capital, corporate governance, risk control, client asset protection, information disclosure, and operational compliance.

From July 1st this year, only crypto-asset service providers that have obtained the corresponding CASP service authorization can legally provide services such as client asset custody, order matching, asset exchange, order execution, and asset transfers within the EU.

It's crucial to note that, strictly speaking, a CASP is not a so-called "all-in-one exchange license." Under the MiCA framework, obtaining a CASP authorization cannot be simply equated with being able to operate a trading platform.

In essence, CASP authorization is granted based on specific service types. This means that the scope of business a platform can conduct depends entirely on which specific service codes it has applied for and been authorized to provide. This is somewhat similar to the business scope on a business license: even within the same CASP authorization regime, the approved business activities of different entities can differ.

Currently, there are 279 entities that have obtained MiCA CASP authorization, of which approximately 222 are major service providers offering crypto trading-related services such as exchange, exchange, or order execution.

However, among these entities, only 18 have actually been authorized to operate a crypto-asset trading platform, specifically receiving authorization under MiCA service category b.

Therefore, understanding the MiCA CASP authorization system requires a closer look at the specific service types it covers.

Below, we provide a detailed breakdown of this aspect.

How are MiCA CASP Authorizations Categorized?

Within the MiCA CASP authorization system, crypto-asset services are subdivided into 10 major categories, corresponding to service codes from a to j. These codes determine the specific business activities a platform is permitted to conduct.

Building on these 10 service categories, MiCA's Annex IV further classifies the minimum capital requirements for CASPs into three tiers: Class 1, Class 2, and Class 3. This tier determines the minimum capital a platform must meet.

The 10 Service Codes

Category a: Custody and administration of crypto-assets on behalf of clients

Category a corresponds primarily to custody services. This involves a platform holding or controlling a client's crypto-assets, or controlling the means of accessing them, such as private keys, account permissions, or custodial wallets.

For CEXs, as long as users deposit their coins into the platform's account, the platform effectively assumes custody responsibilities. The core concerns here are client asset security, private key management, asset segregation, and whether the platform controls the client's assets.

Category b: Operation of a trading platform

Category b is the closest to what is commonly understood as "exchange business." It refers to a platform operating a trading system that allows multiple buyers and sellers to match orders according to the platform's rules. Typical scenarios include order books, matching engines, and multilateral trading facilities.

If a platform only trades with its clients directly, it might not fall under Category b. However, if it facilitates transactions between numerous users via an order book, it falls under the operation of a trading platform.

Category c: Exchange of crypto-assets for funds

Category c refers to a platform using its own capital to exchange crypto-assets for fiat currency (e.g., EUR, USD) with clients. In simple terms, this is when a user buys crypto with fiat or sells crypto to the platform for fiat, with the platform acting as the counterparty. This is similar to what is often called OTC trading.

The key point here is that the platform is not merely matching third-party orders; it is using its own asset pool to perform the exchange between crypto-assets and fiat currency.

Category d: Exchange of crypto-assets for other crypto-assets

Category d corresponds to what is commonly known as crypto-to-crypto trading services. If a platform uses its own capital or asset pool to complete exchanges between different crypto-assets for a client, it falls under this category.

Category e: Execution of orders for crypto-assets on behalf of clients

Category e refers to a platform executing buy, sell, or subscription orders for crypto-assets on behalf of a client. It resembles a brokerage service. Once a user places an order, the platform executes the trade for the client, rather than the user executing it directly on the trading interface. The platform doesn't just receive the order; it actively completes the transaction for the client.

Category f: Placing of crypto-assets

Category f primarily corresponds to issuance-side business. If a platform, on behalf of a project team, issuer, or related party, promotes, sells, or places a specific crypto-asset with investors, it likely falls under this category. Examples include Launchpads, IEOs, and new token distribution services.

Category g: Reception and transmission of orders for crypto-assets on behalf of clients

Category g refers to a platform receiving client orders and then transmitting them to a third party for execution. This can be easily confused with Category e. The difference is that Category e involves the platform executing the order itself, whereas in Category g, the platform merely receives and transmits the order, with the actual execution potentially happening on another platform or through a third party.

Aggregators, order routing platforms, and certain brokerage entry points often involve this type of service.

Category h: Advice on crypto-assets

Category h involves providing personalized advice to clients regarding crypto-assets. This means making specific recommendations (buy, sell, use a specific service) based on the client's individual circumstances, risk profile, and investment objectives. This is more akin to advisory or consultancy services.

Category i: Portfolio management of crypto-assets

Category i corresponds to crypto-asset management. This involves a client authorizing a platform or service provider to manage their crypto-asset portfolio. The key is that the service provider has a certain degree of discretion over the client's asset allocation, meaning they can buy, sell, or rebalance the portfolio on the client's behalf based on the authorization.

Category j: Transfer services for crypto-assets on behalf of clients

Category j refers to a platform transferring crypto-assets from one address or account to another on behalf of a client. Examples include an exchange facilitating a user's withdrawal request, a custodian platform transferring assets for a client, or a payment platform completing crypto-asset transfers for users.

Minimum Capital Classification

Along with the 10 service codes, terms like MiCA Class 1, Class 2, and Class 3 are frequently mentioned in the market.

In fact, Class 1/2/3 are not three different types of MiCA licenses. They are fundamentally a classification of minimum capital requirements defined in MiCA Annex IV.

Class 1 corresponds to services e, f, g, h, i, j. This includes order execution, placing of crypto-assets, reception and transmission of orders, investment advice, portfolio management, and transfer services. The minimum capital requirement is €50,000.

These services are considered more brokerage, advisory, asset management, order transmission, and transfer-oriented. Since they don't necessarily involve the platform holding significant client assets or operating a trading platform, the minimum capital requirement is set at €50,000.

Class 2 builds upon Class 1 by adding services a, c, and d. This means, in addition to the services in Class 1, it also covers client asset custody, exchange of crypto-assets for funds, and exchange of crypto-assets for other crypto-assets. The minimum capital requirement is €125,000.

Class 2 introduces client asset custody and the platform using its own capital for exchanges. It extends beyond basic brokerage, order, advisory, and transfer services to include custody and exchange operations.

Class 3 includes the crucial service b: operation of a trading platform. It can be solely for service b, or it can combine service b with the other services (e.g., building upon all or part of Class 2). Class 3 represents the closest approximation to a full-fledged exchange business. The minimum capital requirement is €150,000.

In summary, the core of MiCA CASP is authorization according to service codes (a to j), which defines the specific crypto-asset services a platform can offer. The Class 1/2/3 classification then sets different minimum capital requirements based on the risk and complexity of those authorized services.

Understanding these rules provides a better basis for assessing which businesses a platform can legally conduct under MiCA.

Authorization Status of Major Crypto Trading Platforms

As of the ESMA update on July 3, 2026 (updated weekly), there are 279 authorized MiCA CASP entities. Aside from Class 1, the vast majority fall under Class 2, with a smaller number belonging to Class 3.

Class 3: Entities Authorized for Service b (Operation of a Trading Platform)

Currently, there are 18 entities that have obtained Class 3 authorization, which includes the service code b for operating a trading platform.

1. OKX

OKX obtained its MiCA CASP authorization through its Maltese entity, OKX Europe Limited, on January 27, 2025. Its service codes are a, b, c, d, e, f, g, i, j, covering client asset custody, trading platform operation, fiat-to-crypto exchange, crypto-to-crypto exchange, order execution, placing of crypto-assets, order reception and transmission, portfolio management, and transfer services. In terms of service code coverage, OKX is among the relatively comprehensive Class 3 platforms.

2. Gate.io EU

Gate.io EU obtained its MiCA CASP authorization through its Maltese entity, Gate Technology Limited, on September 29, 2025. Its service codes are a, b, c, d, e, j, covering custody, trading platform operation, fiat-to-crypto exchange, crypto-to-crypto exchange, order execution, and transfer services.

3. Kraken

Kraken obtained its MiCA CASP authorization through its Irish entity, Payward Global Solutions Limited, on June 25, 2025. Its service code is b, i.e., operation of a trading platform. Note that Kraken also has a separate Class 2 service entity with a different scope of services.

4. BSDex

BSDex obtained its MiCA CASP authorization through its German entity, Baden-Württembergische Wertpapierbörse GmbH, on July 3, 2025. Its service code is b.

5. flatexDEGIRO / 360T

flatexDEGIRO / 360T obtained its MiCA CASP authorization through its German entity, 360 Treasury Systems AG, on April 2, 2025. Its service code is b.

6. PAYMIUM

PAYMIUM obtained its MiCA CASP authorization through its French entity, PAYMIUM SAS, on June 22, 2026. Its service codes are a, b, c, d, e, j, covering custody, trading platform operation, fiat-to-crypto exchange, crypto-to-crypto exchange, order execution, and transfer services.

7. Coinmate

Coinmate obtained its MiCA CASP authorization through its Czech entity, COINMATE a.s., on February 27, 2026. Its service codes are a, b, c, d, j, covering custody, trading platform operation, fiat-to-crypto exchange, crypto-to-crypto exchange, and transfer services.

8. Webot

Webot obtained its MiCA CASP authorization through its Irish entity, Pionew Ireland Limited, on December 18, 2025. Its service codes are a, b, c, j, covering custody, trading platform operation, fiat-to-crypto exchange, and transfer services.

9. RULEMATCH

RULEMATCH obtained its MiCA CASP authorization through its Liechtenstein entity, RULEMATCH Europe AG, on June 1, 2026. Its service codes are a, b, j, covering custody, trading platform operation, and transfer services.

10. Bitstamp

Bitstamp obtained its MiCA CASP authorization through its Luxembourg entity, Bitstamp Europe S.A., on May 15, 2025. Its service codes are a, b, c, d, e, g, j, covering custody, trading platform operation, fiat-to-crypto exchange, crypto-to-crypto exchange, order execution, order reception and transmission, and transfer services.

11. Kanga Exchange EU

Kanga Exchange EU obtained its MiCA CASP authorization through its Latvian entity, SIA AlphaRoute, on June 18, 2026. Its service codes are a, b, c, d, f, j, covering custody, trading platform operation, fiat-to-crypto exchange, crypto-to-crypto exchange, placing of crypto-assets, and transfer services.

12. Anycoin

Anycoin obtained its MiCA CASP authorization through its Czech entity, MP Developers s.r.o., on February 11, 2026. Its service codes are a, b, c, d, e, covering custody, trading platform operation, fiat-to-crypto exchange, crypto-to-crypto exchange, and order execution services.

13. Revolut Crypto

Revolut Crypto obtained its MiCA CASP authorization through its Cypriot entity, Revolut Digital Assets (Europe) Ltd, on October 20, 2025. Its service codes are a, b, c, d, f, j, covering custody, trading platform operation, fiat-to

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