Germany Extends MiCA Lead as ESMA Register Hits 331 CASPs
Germany has pulled further ahead of every other EU member state in the race to authorise crypto asset service providers under the Markets in Crypto-Assets Regulation, after six of its cooperative banks were added to the European Securities and Markets Authority's official register in the latest update. The EU total now sits at 331 authorised CASPs, and Germany alone accounts for 79 of them. For accounting firms, auditors, and CFOs with exposure to regulated digital asset entities, that number has direct implications for counterparty due diligence, audit scope, and ongoing MiCA compliance crypto obligations.
What the Latest ESMA Register Update Actually Says
ESMA updated its MiCA register on 22 August 2026, bringing the authorised CASP count to 331. The six new entrants added in this cycle were all German cooperative banks: Raiffeisenbank Aidlingen, Ihre Volksbank, VR-Bank Mittelfranken Mitte, Volksbank Euskirchen, VR Bank Ried-Überwald, and Volksbank Backnang.
The current ranking by member state
The three largest national tallies at the time of publication are shown below. All figures reflect the ESMA register as updated on 22 August 2026.
| Member State | Authorised CASPs |
|---|---|
| Germany | 79 |
| France | 35 |
| Netherlands | 29 |
Other register datasets: no change
ESMA's asset-referenced token (ART) register remained empty. The electronic money token (EMT) register was unchanged at 43 entries. The non-compliant entity list also held steady at 167. The absence of movement in the ART register is notable given that stablecoin issuance remains one of the more actively watched areas of MiCA implementation, but no new ART authorisations have been recorded to date.
Why Germany Is So Far Ahead
The gap between Germany and the rest of the EU is not accidental. Germany's Federal Financial Supervisory Authority, BaFin, explained its position publicly in June 2026, identifying two structural reasons for the high CASP count.
A large credit institution base
Germany has one of the densest networks of licensed credit institutions in the EU, a legacy of its cooperative banking and savings bank (Sparkasse) model. Credit institutions that already held a national licence were eligible to provide crypto asset services under MiCA without needing a separate, standalone CASP authorisation. The six banks added in this latest update are all cooperative institutions, which reinforces BaFin's point about the breadth of the eligible domestic base.
The national transition regime advantage
Germany operated a pre-MiCA national crypto custody licensing regime, and BaFin confirmed that some providers were able to access a simplified authorisation procedure during the transition period. Entities that had already satisfied rigorous national requirements could, in effect, convert rather than start from scratch. That pathway has no equivalent in markets that lacked a comparable domestic framework before MiCA's full application date.
France and the Netherlands have their own strong supervisory cultures, but neither country's transition arrangements produced the same volume of authorisations. France's CASP count of 35 likely reflects the structure of its Digital Asset Service Provider (PSAN) regime, which required separate registration rather than conversion from a credit institution licence. The Dutch AFM regime took a similarly distinct path.
Implications for Accounting and Audit Teams
The steady expansion of the ESMA register is not just a regulatory headline. It generates concrete work for accounting firms, auditors, and in-house finance teams across the EU.
Counterparty status and due diligence
Under MiCA, transacting with or through a CASP requires that entity to be on the ESMA register. For accounting firms advising clients that hold digital assets on custodied platforms, the register is the primary tool for verifying counterparty authorisation status. A client using a service not on the list is exposed to potential regulatory breach, and the firm advising that client carries reputational and professional risk if it fails to flag it.
The non-compliant entity list, currently at 167 entries, is the inverse of the authorised register and deserves equal attention. Any entity appearing on that list should trigger immediate review of existing relationships, transaction histories, and related disclosures in financial statements.
Audit scope and financial statement disclosure
For auditors, the ESMA register now functions as an authoritative reference for assessing whether a client's crypto asset custodian or trading platform is operating legally. Where a client holds material digital assets with a non-authorised entity, that raises going-concern questions about the security of those assets, the robustness of internal controls, and the accuracy of balance sheet carrying values. Firms using robust crypto accounting software should be building CASP authorisation checks into their client onboarding and ongoing monitoring workflows, not treating them as a one-off exercise.
AML and transaction monitoring obligations
CASPs on the ESMA register are subject to MiCA's full AML and KYC requirements, including the application of the Transfer of Funds Regulation to crypto asset transfers. For accounting teams and compliance officers at regulated entities, the expanding register means a growing pool of counterparties from whom Travel Rule data should be receivable. Where that data is absent or incomplete, it is a red flag that warrants investigation. The six cooperative banks added this week are small regional institutions; firms that encounter them as counterparties should confirm their authorised status directly against the ESMA register before processing transactions.
You can find a broader analysis of the MiCA authorisation landscape across EU member states in our earlier coverage, which covers illicit exposure risk among authorised and non-authorised providers.
What CFOs and Finance Directors Should Do Now
The register update cycle is not a quarterly event. ESMA updates the register on an ongoing basis, and the pace of additions has accelerated through 2026. A static point-in-time review of counterparty authorisation status is insufficient. CFOs overseeing treasury functions or investment portfolios that touch digital assets need a monitoring process that reflects live register data.
Practical steps for finance teams
First, pull the current ESMA MiCA register and cross-reference every crypto-related counterparty, custodian, and trading venue your entity uses. Second, check the non-compliant entity list for any overlap. Third, review any disclosure notes in your most recent financial statements that reference digital asset service providers, and assess whether those entities remain authorised. Fourth, update your supplier due diligence policy to include periodic ESMA register checks, with a defined frequency tied to the materiality of the exposure.
For firms advising multiple clients with digital asset exposure, deploying digital asset accounting software that integrates compliance status tracking alongside transaction recording will reduce the manual overhead of these checks substantially. The ESMA register is publicly available and machine-readable; there is no reason to run these checks manually at scale.
Understanding how MiCA intersects with DeFi accounting obligations is equally important for firms whose clients are engaged with decentralised protocols, since the CASP register does not capture that segment of the market.
The Bigger Picture: What the Register Trajectory Signals
Germany's jump from 57 CASPs in late June to 79 in late August represents a significant acceleration. The addition of six cooperative banks in a single register update suggests that the pipeline of transition-period applicants has not yet cleared. BaFin's simplified conversion pathway may still have outstanding applications working through the system, and further additions from Germany's cooperative and savings bank sector are plausible in coming months.
At the EU level, a total of 331 authorised CASPs is a substantial market. It creates a licensed infrastructure that did not exist three years ago, and it provides a foundation for the cross-border passporting that MiCA enables. A CASP authorised in Germany can, in principle, passport its services into France, the Netherlands, or any other EU member state without seeking a separate licence in each jurisdiction. That passporting dynamic means the German register count has relevance well beyond Germany's own borders.
For compliance teams, the growing register also has a practical upside: it makes it easier to identify which entities are operating lawfully and which are not. The 167 entries on the non-compliant list represent a known universe of unlicensed providers, and the gap between that list and the authorised register is narrowing as more legitimate operators complete their authorisations.
The trajectory of the EMT register, currently at 43 entries and unchanged in this update, will be worth watching. Electronic money tokens are the MiCA category that captures most euro-denominated stablecoins, and the stability of that count at 43 suggests that the major issuers have settled into compliance while new entrants have not yet appeared at scale. Any change in that count will warrant close attention from treasury and payments teams.
Frequently Asked Questions
What is the ESMA MiCA register and why does it matter for accounting firms?
ESMA maintains a public register of all entities authorised to provide crypto asset services under MiCA. Accounting firms use it to verify the regulatory status of counterparties, custodians, and trading platforms their clients interact with. An entity not on the register is not permitted to provide CASP services in the EU, making the register a key due diligence tool.
Why does Germany have so many more authorised CASPs than other EU member states?
Two structural factors explain it. Germany has a very large credit institution base, including hundreds of cooperative and savings banks that were already licensed domestically and eligible to add crypto services under MiCA. Germany also had a pre-existing national crypto custody regime, which allowed some entities to follow a simplified conversion pathway rather than a full fresh authorisation.
What is the non-compliant entity list and how should finance teams use it?
The non-compliant entity list is ESMA's published register of entities found to be operating crypto asset services without proper authorisation. Finance teams should screen all existing and prospective crypto-related counterparties against this list. Any match should trigger an immediate compliance review, potential relationship termination, and assessment of whether any financial statement disclosures need to be revised.
What does it mean that the ART register is still empty?
Asset-referenced tokens, which include most commodity-backed and basket-backed crypto assets, require a specific authorisation under MiCA. The fact that no ART authorisation has been granted to date indicates that either no issuer has yet completed the process or no applicant has met the requirements. Entities planning to issue or hold ARTs should treat this as a signal that the authorisation bar is high and plan accordingly.
How often does ESMA update the MiCA register?
ESMA updates the register on a rolling basis rather than on a fixed calendar. Given the pace of additions observed through 2026, firms should treat their counterparty register checks as a live monitoring obligation rather than a periodic compliance exercise.
Source: Cointelegraph