On the MiCA registration list maintained by the European Securities and Markets Authority (ESMA), banking-related institutions account for 23%, approaching one quarter. At the end of June, the figure was still only about half; it doubled within three months.
MiCA is the EU’s regulatory framework for crypto-asset markets. If anyone wants to do crypto business in compliance with the EU’s 27 countries, they basically need to be on this list. When I was looking at the numbers, my first reaction was: wasn’t this list previously the domain of exchanges and custodians?
It’s not like that anymore.
Compared with another matter, it’s even more interesting. On September 18 (reported by The Wall Street Journal), ECB President Christine Lagarde personally intervened and stopped Binance’s MiCA license. Under the MiCA framework, the ECB does not have formal approval power over licenses, but after pressure from senior leadership, Greece withheld an application that its regulators had previously deemed “complete.”
On one side, banks queue to enter; on the other, leading exchanges are talked out of it by phone.
Binance getting an EU license has been dragging on for more than a day or two. Greece was originally a breakthrough point—getting the application all the way to the “complete” stage suggests there weren’t major issues on the technical review level. A phone call from Lagarde, and the process just stops there. ECB hostility toward crypto is no secret—she publicly said in 2023 that Bitcoin was “worthless.”
But once banks come in, she doesn’t stop them.
This is MiCA’s design orientation. It opens a familiar compliance pathway for banks, payment institutions, and custodial banks—these institutions are already within the ECB and national central banks’ regulatory orbit. Capital adequacy ratios, anti–money laundering, governance structures—all of it is ready-made. For an exchange to enter this circle, it would have to build a whole new regulatory trust from scratch—high cost, and approval is far from guaranteed.
On the list, the share of banks doubled from the end of June to mid-September to 23%. The speed shows banks aren’t just testing the waters. They’re treating MiCA compliance licenses as a new moat.
The logic of the moat is simple: MiCA licenses themselves have capital thresholds, local entity requirements, and ongoing compliance costs. Banks have scale advantages in doing these things, while exchanges face pure incremental expense. Once licenses are issued to a fair number of players, latecomers won’t just face regulatory scrutiny—they’ll also run into the first-mover position of already-licensed banks in custody, payments, and tokenized deposits.
JPMorgan and Citi have already been transferring tokenized deposit operations among institutions, limited to their own branch networks and not touching retail. This is the most comfortable posture for banks—to use existing licenses for incremental business without changing the core structure.
Binance doesn’t have that posture. Its entity is offshore, its users are global, and compliance entities have to be set up one by one. With Lagarde’s move in Greece, the one being blocked isn’t just Binance—it’s all exchanges that “do the business first and fill in the licensing later.”
On the flip side in the US, the CLARITY Act didn’t get passed in the Senate. The CFTC and SEC instead push rulemaking forward using existing authorities. On September 18, the CFTC sent crypto market rules to the White House for review, and the SEC also opened a new path for tokenized stock trading. Coinbase and Kalshi filed applications for US stock perpetual futures on the same day.
The US is where regulators rush to fill legislative gaps; the EU is where banks rush to fill licensing gaps. Two markets, same direction: compliance entry is narrowing, and the pool of players who can get in is shrinking—while banks are one of the few groups already holding entry tickets.
Will that 23% on the MiCA list keep rising, and how high it can go before it’s considered stable—I don’t have the answer. But there’s one thing I’m watching closely: once banks have gotten custody, payments, and tokenized deposits working, for an exchange to then try to obtain an EU license, it won’t just be a phone call from Lagarde anymore.
By then, if a trading platform wants to do compliance business in Europe, should it go apply for a license—or should it go find a licensed bank to do it as a white-label partner?