The Race for the First MiCA Licenses (2025): Which Countries Will Lead the Way?
The Markets in Crypto-Assets Regulation (MiCA) is often hailed as the defining legal framework for EU crypto regulation, promising a single, harmonized market for Virtual Asset Service Providers (VASPs) across all 27 member states. With the core provisions regarding the CASP authorization (Crypto-Asset Service Provider) expected to take effect in late 2024 and early 2025, the industry is now focused on a crucial question: Which countries will be the first to actually issue MiCA licenses, and why?
The rollout of MiCA is not a centralized process executed by the European Securities and Markets Authority (ESMA). Instead, the power lies with the Competent National Authorities (CNAs)—the national financial regulators in each member state (e.g., BaFin in Germany, AMF in France, MFSA in Malta). These CNAs are responsible for interpreting MiCA, managing the application intake, conducting due diligence, and ultimately granting the EU MiCA license.
The race to be the first to issue licenses is highly strategic. The first jurisdictions to prove their competence and speed will attract the most capital, the largest operators, and the most specialized FinTech innovation. This 2,500-word analysis delves into the readiness of the leading contenders—Malta, France, Germany, and Ireland—predicting which nations are best positioned to dominate the initial wave of MiCA Passporting in 2025.
MiCA Implementation—The Starting Gun
The Defining Moment of 2025: CASP Authorization
MiCA’s implementation is staggered. While the rules for stablecoins and crypto-asset reference tokens (ARTs/EMTs) often come first, the full weight of the MiCA implementation timeline falls on the CASP authorization framework, which covers exchanges, custody providers, advisory services, and portfolio management.
Once a VASP secures a MiCA license from its home CNA, the MiCA Passporting mechanism immediately allows that firm to operate in any other EU/EEA jurisdiction without needing subsequent local licenses. This is the mechanism that transforms the European crypto landscape from a regulatory patchwork into a unified market.
The Competent National Authority (CNA) Advantage
The speed of license issuance depends entirely on the preparedness and philosophical approach of the local CNA. We can categorize the contenders based on their existing regulatory history:
The Fast Movers (Pre-MiCA Regimes): Jurisdictions that already implemented their own comprehensive licensing or registration frameworks before MiCA. They have existing infrastructure, trained personnel, and active applications to convert. (e.g., France, Malta)
The Conservative Titans (Strict Interpretation): Jurisdictions that already had rigorous national laws but whose focus is primarily on financial stability and prudence. They may be fast because they have already cleared out most non-compliant entities, but slow due to intense scrutiny. (e.g., Germany, Ireland)
The Institutional Hubs (Niche Focus): Jurisdictions primarily targeting large financial institutions, focusing on the quality and stability of applicants rather than volume. (e.g., Luxembourg)
The race is not merely about being the fastest; it’s about attracting the right type of operator. The quality of the first licenses issued will define the global reputation of that CNA under the MiCA regime.
The Frontrunners—France and Malta
These two jurisdictions are highly motivated and possess the necessary legislative infrastructure to convert existing registrations into MiCA CASP authorizations quickly.
France: The PSAN Head Start and Political Will
France has positioned itself as a progressive FinTech innovation hub, and its regulator, the Autorité des Marchés Financiers (AMF), has been proactive.
The PSAN Advantage
France introduced the Prestataire de Services sur Actifs Numériques (PSAN) status well before MiCA. This regime requires registration for VASP compliance and, critically, voluntary licensing for certain services.
The Conversion Path: Existing registered PSANs already comply with many of MiCA’s core requirements regarding governance, cybersecurity, and AML/KYC procedures. The AMF is therefore tasked with converting these existing, pre-vetted files into MiCA-compliant files, a much shorter process than reviewing a brand-new application.
Political Momentum: The French government has thrown its weight behind making Paris a global crypto hub. This strong political incentive translates into a faster allocation of resources and staffing at the AMF to expedite the initial batch of MiCA licenses.
Prediction: France is likely to be among the first countries issuing MiCA licenses for the core exchange and custody categories, focusing on speed to capture global market attention.
Malta: Leveraging VFA History and Operational Volume
Malta’s journey into crypto regulation started early with the controversial yet pioneering Virtual Financial Assets (VFA) Act. While the VFA framework has seen mixed success and required significant restructuring to align with MiCA, the island nation has deep operational experience.
The VFA Act Conversion
The Maltese Financial Services Authority (MFSA) already has thousands of hours of experience dealing with crypto exchange operators, compliance manuals, and the specifics of blockchain technology.
Existing Pipeline: Malta holds a substantial existing pipeline of companies with a Maltese corporate structure actively waiting for the MiCA transition. The MFSA knows these applicants well and has already conducted substantial due diligence.
The MiCA Alignment Challenge: Malta’s existing framework was sometimes criticized for being complex and overly bureaucratic. The MFSA has been diligently working to simplify its procedures and align them seamlessly with MiCA, positioning the island to return to prominence as an iGaming and crypto licensing hub.
Prediction: Malta will be a high-volume issuer. While the first single license might go to France, Malta is likely to issue the largest number of CASP authorizations in the first half of 2025 due to its immense existing operational pipeline.
The Conservative Titans—Germany and Ireland
Germany and Ireland represent jurisdictions with impeccably strong financial reputations, where the focus is firmly on institutional stability and investor protection, often at the expense of speed.
Germany: BaFin’s Strict Krypto-Verwahrung
Germany, through its financial watchdog BaFin, has been a pioneer in national crypto regulation, specifically with its Krypto-Verwahrung (Crypto Custody) license, introduced in 2020. This framework is arguably the strictest pre-MiCA law in Europe.
The BaFin Dilemma
High Barrier to Entry: Because the BaFin Krypto-Verwahrung license is so demanding—requiring significant capital, operational separation, and high-level cybersecurity protocols—few companies have successfully obtained it. Those that have are typically large, well-funded financial services entities.
Conversion Speed: BaFin’s existing licensed firms are already operating at a standard far exceeding the MiCA minimums. For these entities, the conversion to a MiCA license will be rapid, as their core processes are already approved.
New Entrant Slowness: However, for new applicants who were previously operating under lighter registration regimes elsewhere, the full BaFin assessment for a CASP authorization will be intensely rigorous and time-consuming. Germany is predicted to be fast for its existing license holders but slow for new international entrants.
Prediction: Germany will issue some of the first, highest-quality institutional MiCA licenses, solidifying its role as the preferred jurisdiction for major Tier 1 banking partners entering the crypto custody space.
Ireland: The Stability-First Approach of the CBI
Ireland, as a major global technology and finance hub, is under immense international scrutiny. The Central Bank of Ireland (CBI) has demonstrated a strong, cautious approach to VASP registration, prioritizing financial stability and preventing regulatory capture.
Rigorous VASP Assessment: The CBI’s VASP registration process has been notoriously slow, demanding substantial documentation and organizational readiness. This suggests the CBI will adopt an equally thorough, “safety-first” approach to the MiCA CASP authorization.
Focus on Governance: Ireland is likely to focus heavily on MiCA’s governance requirements, ensuring applicants have clear organizational structures, robust internal controls, and sufficient capital.
Prediction: Ireland will likely not be among the very first to issue licenses due to the CBI’s inherent caution. However, the licenses it does issue will carry an extremely high degree of regulatory credibility, making them highly attractive to US and international FinTech companies seeking a trusted EU base for MiCA Passporting.
The Institutional Gateway—Luxembourg
Luxembourg, through the Commission de Surveillance du Secteur Financier (CSSF), has always been a key jurisdiction for institutional finance, wealth management, and highly compliant custody solutions.
Focused on High-Value, Institutional CASPs
Luxembourg’s existing regulatory framework (particularly regarding Payment Institution licenses and specific AML requirements) positions the CSSF to focus its MiCA efforts on institutional clients.
Professionalization of Crypto: The CSSF will likely prioritize applications from existing financial firms (banks, investment funds, established asset managers) looking to add MiCA CASP services, especially custody, to their existing portfolio.
High Standards: Like Germany, Luxembourg is conservative and will demand high levels of organizational and technical compliance. The process will be focused less on volume and more on the structural robustness of the applicant.
Prediction: Luxembourg will be among the first to issue licenses for specialized services like crypto-asset portfolio management and transfer services to institutional clients, leveraging its powerful position in the European funds industry.
Why Being First Matters—A Strategic Analysis
The race to be the first country issuing MiCA licenses is fundamentally a geopolitical and economic competition.
Attracting FinTech Capital and Talent
Jurisdictions that demonstrate speed, clarity, and consistency in the MiCA application process will immediately become magnets for global VASP operators. Fast issuance means faster market access via MiCA Passporting, leading to immediate revenue generation for the applicant and tax revenue for the host nation.
Setting the Regulatory Interpretation Standard
MiCA is a regulation, but its interpretation often involves national discretion. The first CNAs to issue licenses will, in effect, set the practical standard for how certain requirements—like sufficient initial capital or specific MiCA compliance documentation—are interpreted. Subsequent CNAs will look to these early movers for precedent.
MiCA Transitional Period Strategy
Many countries have adopted the maximum MiCA transitional period (up to 18 months, depending on the service) for existing VASP applicants to ease the conversion. The CNAs that use this period effectively—conducting rigorous FMA due diligence and preparatory audits—will be the ones issuing the final, compliant licenses swiftly in 2025, maximizing both speed and stability.
Forecasting the MiCA 2025 Landscape
The MiCA 2025 environment will launch with intensity, defined by the preparatory work done by the national regulators.
Based on current regulatory structures, political incentives, and existing applicant pipelines, the forecast for the initial wave of CASP authorizations is: