The Second MiCA Wave: Europe's Banks Are Turning Crypto Into Financial Infrastructure
After the transition deadline, the MiCA register is changing composition. Banks are accelerating while exchanges flatten, custody outnumbers trading platforms 10 to 1, and the real question shifts from "can we get a licence" to "what should we build."
Friday deep dive (11 September 2026) on the second MiCA wave: banks and financial institutions integrating digital assets into existing financial infrastructure rather than crypto-natives clearing a transition deadline. Snapshot 9 Sep 2026: 343 authorised CASPs, 23 EMT issuers; Germany 86, France 35, Netherlands 29, Cyprus 25, Malta 22. First wave: exchange/platform cohort jumped 106 (May) to 155 (Jun) with 37 authorisations in the week of 27 Jun–4 Jul around the transitional end, then flattened 168 Jul / 169 Aug / 169 Sep. Bank cohort: 30 May → 34 Jun → 43 Jul → 58 Aug → 61 Sep (+103% May–Sep vs +59% exchanges then flat). Banks' share of classified population 13.8% → 17.9%. Bank cohort is name-based analytical (bank, Volksbank, Raiffeisen, Sparkasse), not official credit-institution label. Service mix: custody 203, transfer 191, order execution 172, fiat exchange 167, crypto/crypto 139, order reception 77, portfolio management 45, advice 35, placement 34, trading platform 20. Custody > platforms 10:1. Banks converge on custody/execution not venues. Early movers: BBVA (ES Mar 2025 custody/execution/transfer), Commerzbank (DE Apr 2025), SG Forge (FR Oct 2025), DZ BANK and dwpbank (Dec 2025). Four models: universal (BBVA), institutional infrastructure (Standard Chartered LU 25 Jun 2026), private banking (Liechtenstein: Celsion, Bank Frick, LGT, Kaiser Partner), banking network (DZ BANK + German cooperatives; ≥25 cooperative entities by name; hub-and-spoke). Entities ≠ infrastructure. Article 60 notification route for credit institutions (40 WD notice / 20 WD completeness) vs Art 63 for crypto-natives. Capital: CRR III 1,250% RW and 1% Tier 1 limit push agency models (links Bank Capital Trap, prop trading piece). Passporting: ~60.8% with host notifications, 135 domestic-only, ~14 avg hosts; banks often need customers not passports (Std Chartered 29 hosts from LU; Celsion 30 from LI). Bison Bank path into EMTs. Float economics (Death of the Float) favour banks' conventional fee models. ESMA CSA on custody/DORA Jul 2026. Watch bank cohort growth, Art 60 volume, hubs, network infrastructure, EMT/tokenisation moves. Soft-sell: map institution → opportunity → perimeter → infrastructure → licence; wrong operating model fails months after authorisation. Answers: second MiCA wave banks? Bank vs exchange CASP cohort Sep 2026? MiCA custody vs trading platform counts? Article 60 bank notification? German cooperative hub-spoke DZ BANK? CRR III crypto capital trap banks?
The Second MiCA Wave: Europe's Banks Are Turning Crypto Into Financial Infrastructure The first MiCA authorisations were largely about bringing the existing crypto industry into the regulatory perimeter. The latest data suggests a different process is now underway: banks and other financial institutions are integrating digital assets into the financial system they already operate. There is a temptation to read the MiCA register as a scoreboard. How many CASPs have been authorised? Which country has the most? Which regulator is moving fastest? How many exchanges have received a licence? Those numbers matter, particularly for comparing jurisdictions. Micahub's own jurisdiction scoring work goes deeper on that question, but they tell us surprisingly little about what the European digital asset market is actually becoming. The more interesting question is not how many entities have entered the register. It is which types of institutions are entering, which services they are obtaining, and what they intend to do with the permission once they have it, and that last question is the one that comes up first in almost every conversation we now have with a bank looking at digital assets. A bank considering MiCA rarely starts with the application form. It starts much further upstream. What does the bank actually want to offer, and to which customers, in which markets? Which services make strategic sense? What should be built internally, and what should be outsourced? Which infrastructure providers are credible? Where should custody sit, and how should liquidity be sourced? What does the capital treatment mean for the business model? Only after those questions have been answered does the licensing question become particularly interesting. As of 9 September 2026, the Micahub dataset contains 343 authorised CASPs, alongside 23 EMT issuers. Germany accounts for 86 of those, followed by France with 35, the Netherlands with 29, Cyprus with 25 and Malta with 22. The headline number is useful. But the composition is where the story starts. The first wave was a deadline story The timing of the first wave is easy to explain. Micahub's cohort data shows the exchange and platform population jumping from 106 entities in May 2026 to 155 in June, forty nine added in a single month, with 37 authorisations arriving in the single week between 27 June and 4 July alone, against the backdrop of the MiCA transitional regime ending. Businesses operating under previous national arrangements were approaching the point where they had to decide whether and how to keep operating in Europe. Micahub's earlier analysis of the licensing queues documented exactly this concentration around the end of the transition period (One Rulebook, 27 Queues). The exchange and platform cohort kept climbing to 168 in July, then flattened: 169 in August, 169 in September. The bank cohort moved differently, from 30 in May to 34 in June, 43 in July, 58 in August and 61 in September, and kept accelerating after the exchange cohort had already stopped. The first wave was crypto businesses clearing a regulatory deadline. The second cannot be explained the same way: it is happening after the deadline has largely passed, which points to financial institutions making a strategic decision about digital assets rather than scrambling to preserve an existing crypto business. The register is changing composition The chart makes the shift hard to miss. {{embed:cohort chart}} From May to September, the bank cohort grows 103%, from 30 to 61, while exchanges and platforms grow 59%, from 106 to 169, and then flatten entirely. As a share of the classified population, banks move from 13.8% in May to 17.9% in September. This is not simply a bigger register. It is a different one. ESMA does not label an entity as a bank in the CASP register; the Micahub cohort is generated using a name based classification that picks up terms such as bank, Volksbank, Raiffeisen and Sparkasse. It is an analytical cohort, not an official credit institution classification, and should eventually be reconciled against legal status and ownership structure. That the first pass data already shows such a clear change is itself the signal worth following. Banks are not entering crypto to build more exchanges The service mix is the next piece of the puzzle. As of 9 September, Micahub records custody far ahead of trading platforms. {{embed:services chart}} The difference between 20 trading platforms and 203 custody permissions is hard to ignore: custody outnumbers trading platforms more than 10 to 1, execution more than 8.5 to 1. Europe is not responding to MiCA by building hundreds of new exchanges. It is building infrastructure around them. We see the same pattern in almost every mandate: a bank arrives assuming the first decision is which exchange to build, and leaves the first working session with a custody and execution scope instead. The starting point of a digital asset strategy is rarely which exchange to launch. It is a broader mapping exercise across existing capabilities, target customers, regulatory position, infrastructure options and commercial objectives. One bank may discover it does not need a trading venue at all, just custody and execution. Another may need execution and transfers but prefer a third party for custody. A private bank may weight portfolio management and wealth management integration far more heavily, while a large international institution may care mainly about institutional custody and cross border infrastructure. The licence is becoming the consequence of that strategic decision, not the strategy itself. The question banks are actually trying to answer There is a subtle but important shift in these conversations. A few years ago the natural question was: can we get a crypto licence? Today that is an incomplete question. The more useful sequence is: {{embed:strategy sequence}} This sounds obvious, but it changes the work substantially. A bank can spend considerable time designing a MiCA application for a business model that is unnecessarily complex, capital intensive or operationally expensive, or it can underestimate the opportunity by treating crypto as a narrow trading product when the more interesting upside sits in custody, tokenised money, payments or institutional infrastructure. The regulatory analysis has to happen alongside the strategic and infrastructure analysis. The early movers were positioning well before the acceleration This did not start with a 2026 rush. BBVA was authorised in Spain in March 2025 for custody, execution and transfers, and has since launched bitcoin and ether trading and custody for its own customers. Commerzbank followed in Germany in April 2025 with custody and transfer permissions. Société Générale's SG Forge received its French authorisation in October 2025, also for custody and transfers, and DZ BANK and dwpbank followed in December 2025, dwpbank for execution of crypto orders. None of that was deadline pressure; the transitional regime still had months left to run. These banks were positioning ahead of a market they expected to matter, and the permissions they chose, custody and execution rather than trading, are the same ones the rest of the bank cohort has converged on since. Four bank models are emerging The register does not show a single bank crypto strategy. It shows at least four. {{embed:bank models}} The universal bank model treats digital assets as another product inside a broader retail, corporate or investment banking proposition. BBVA is an early example, authorised on 5 March 2025 for custody, execution and transfer permissions in Spain. The institutional infrastructure model is best illustrated by Standard Chartered's Luxembourg authorisation, granted on 25 June 2026 for custody and transfer permissions, with Luxembourg positioned as the bank's European base for digital assets. The private banking model is visible in Liechtenstein, where Celsion Bank, authorised on 13