EU payment licences for crypto firms: what changed in 2026

If you run a crypto business in the EU that moves euro stablecoins for customers, a MiCA authorisation is no longer the whole licensing answer. Since 2 March 2026 the EBA expects firms handling e-money tokens as payment services to hold, or be actively securing, a PSD2 payment licence as well. The EU payment licence is now a crypto licensing decision, and the 2026 authorisation data shows founders have noticed.

Why do crypto firms need an EU payment licence?

MiCA authorises crypto-asset service providers (CASPs). It does not replace PSD2 for services that count as payment services. In its 12 February 2026 opinion the EBA said that CASPs providing e-money token (EMT) services that qualify as payment services need PSD2 authorisation, and that the nine-month no-action period first published on 2 June 2025 ended on 2 March 2026. After that date, national authorities may let a firm carry on without the licence only if it meets the conditions in the opinion. Firms that do not meet all of them must stop those services. The EBA also noted that more than 100 CASPs had already approached national authorities or applied.

For a founder, the practical point is sequencing. A CASP licence covers custody, exchange and transfer of crypto-assets. If your product also moves EMT value between customers or to third parties, you should test it against the payment services definitions early, before you commit to a home state.

What the 2026 licence figures show

HaiPay, a payments firm, matched the EBA PSD2 register (bulk download of 21 October 2026) against the ESMA interim MiCA register (file modified 19 October 2026). This is third-party analysis, not an official statistic, and it matches on legal name and home country, so treat it as indicative. Its findings:

Of 112 new EU and EEA payment and e-money licences granted between 1 January and 21 October 2026, 51 went to firms that also appear on the MiCA register.
That compares with 4 of 57 in the same period of 2025, and 6 of 67 across the whole of 2025.
Of the 51, France accounts for 14, Malta 11 and Luxembourg 6.
Of the 27 e-money licences in the period, 8 went to MiCA-registered firms. The larger share, 43 of 85, was payment institution licences.

HaiPay's own caveat is worth repeating: being on the MiCA register does not show that a firm uses its payment licence for crypto activity. Non-crypto licences also rose, from 53 to 61 on its count, so the market is not simply a crypto story.

What this means for your licensing route

Three decisions follow. First, decide whether your product is a payment service or an e-money issuance at all, because that determines whether you need a payment institution licence, an EMI licence, or neither. Second, compare home states on both regimes together. Malta, France and Luxembourg lead the 2026 counts, and our e-money comparison lets you set them against each other, while the Malta crypto entry covers the CASP side. Third, build the dual application timeline into your plan, since two authorisations rarely move in step.

If you need a view on how your own structure maps to both regimes, a bespoke report answers your exact question.

This article is informational only and is not legal advice. Check your position with qualified counsel before acting.

Sources

Informational only, not legal advice. Verify with the relevant regulator and qualified counsel before acting.