100 days of MiCA after the grandfathering deadline

MiCA's transitional period ended on July 1, 2026. With it, the EU digital asset market finished its shift from a patchwork of national regimes to a single regulatory framework.

Of the 2,747 crypto registrations under national regimes in 2024, only 280 firms appeared on ESMA's first post-deadline list.

That number made the headlines, but in our view it was not the most consequential one. For most of crypto's history, the market was shaped by exposure to USD-based flows. The period after July 1 revealed a structural remaking that set off a race to build genuine euro liquidity at a meaningful scale.

Finery Markets analysed over 16 million institutional spot crypto trades executed on its technology platform in the first nine months of 2026. Based on this data, we tracked how euro liquidity evolved under regulatory tailwinds.

We reached out to Banking Circle, Fipto, The Vault, and Sumsub to learn how the first 100 days have affected stablecoins, custody, payments, trading, and compliance.

Key ideas and numbers:

Institutional OTC volume on Finery Markets' platform grew 57% year on year in the first 9 months of 2026, while top-20 centralised exchange volume fell 47%. Stablecoins accounted for 83% of trades by number.
Finery Markets expects MiCA to bring the kind of consolidation that followed MiFID II in 2018. Just as MiFID II squeezed niche brokers out of equities and fixed income, MiCA is pushing execution towards institutional-grade infrastructure built for bank-level scrutiny.
Fipto says many firms that missed the 1 July authorisation deadline have not left the market. The compliant route has been to partner with a licensed CASP, which contracts directly with the end client and carries the regulatory responsibility.
Banking Circle argues that reserve caps should target the quality of safeguards, not the size of the bank. Under the EBA's double test, an issuer placing €1bn of reserves with smaller banks would need at least 20 of them. The bank says that for an issuer entering the EEA market, managing this many banking relationships would be a significant operational burden.
Euro stablecoin supply has risen 22.6% this year to $848 million, while dollar supply has been broadly flat, according to Token Terminal. Euro supply is still about 0.3% of the dollar-linked stablecoin market.
MiCA has sparked a battle for native euro liquidity. EURC volume on Finery Markets' platform rose 46-fold year on year in the first 9 months of 2026, though it still accounts for just 0.12% of stablecoin volume.