H1 2026 was the half in which crypto licensing stopped being a promise and became a scoreboard. MiCA's EU-wide transitional backstop expired on 1 July 2026, and by mid-year roughly 244 CASP authorisations had been granted across the EU. The distribution is the story: Germany alone holds around 57 of them, roughly 23 per cent of the EU total, while Lithuania, the previous cycle's registration capital, had authorised only about 4 CASPs by March. The licensing map of Europe has been redrawn in eighteen months, and it looks nothing like the VASP era.
Our read: the market has split into three tiers. Volume hubs (Germany, the Netherlands, France) where authorisation is demanding but well trodden; selective gateways (Ireland, Malta) shaped by supervisory scrutiny, including ESMA's July 2025 peer review of the MFSA; and the long tail, where legacy registers wound down faster than replacement authorisations arrived. Anyone still choosing a jurisdiction in H2 2026 is choosing between tiers, not just fee schedules.
Europe: the transition endgame
The staggered national windows did exactly what staggered windows do: they moved firms. Lithuania ended legacy VASP cover on 1 January 2026, six months before the EU backstop. Ireland's transitional period closed on 30 December 2025 with around 10 CASPs authorised, Kraken and Coinbase among them. Austria set 30 June 2026, one day inside the default. France and Malta ran to the full 1 July 2026 deadline, with France reaching roughly 18 authorisations by late May and Malta around 13, its first-mover licence to a major exchange dating back to January 2025.
Germany's twelve-month grandfathering, with applications due by 8 October 2025, produced the EU's largest CASP hub: banks and neobrokers (Commerzbank, N26, Trade Republic) sit alongside crypto natives. The Netherlands became one of the highest-volume jurisdictions through H1, authorising Bitvavo, Amdax, MoonPay and Finst among others.
Which jurisdictions got harder in H1 2026?
Scrutiny tightened faster than fees rose. ESMA's peer review of Malta's authorisation practice put every fast-track regulator on notice. The AMF adopted ESMA's staff knowledge and competence guidelines in March 2026. Dubai's VARA reissued all twelve rulebooks in its Rulebook 2.0 exercise and penalised roughly 19 unlicensed firms, backing the new rules with an AML circular in March and token-issuance guidance in April 2026. Singapore's DTSP regime, live since 30 June 2025, remains the half's bluntest signal: overseas-only crypto firms need a licence MAS has said it will generally not issue, and MAS revoked a major payment institution licence in May 2026.
The UK finally set its clock
The other defining H1 development was British. Statutory Instrument 2026/102, made on 4 February 2026, fixed the cryptoasset regime's legal architecture, and the FCA published its final rulebook on 30 June 2026 in three policy statements covering stablecoins, regulated activities and prudential requirements. The authorisation gateway opens 30 September 2026 and closes 28 February 2027, ahead of a mandatory FSMA regime from 25 October 2027. UK-active firms now have real dates and a real filing window, and the queue forms this autumn.
Beyond Europe
Hong Kong granted its first two stablecoin issuer licences on 10 April 2026 under the Stablecoins Ordinance, to HSBC and Anchorpoint. Japan's Cabinet approved an FIEA amendment bill on 10 April 2026 that would reclassify crypto-assets as financial instruments, importing insider-dealing and disclosure rules. South Korea promulgated Act No. 21358 in February 2026, effective 20 August 2026, removing the Travel Rule de minimis threshold and expanding VASP entry screening. In the US, the GENIUS Act's stablecoin framework (signed July 2025) began reshaping issuer structures while the CLARITY Act's market-structure package worked through the Senate during the half.
E-money moved just as much
The parallel regime had its own landmark half. PSD3 and the PSR reached final published texts on 23 April 2026: EMD2 will be repealed and the standalone EMI category folded into a payment institution licence authorised to issue e-money, with transposition running about 18 months from Official Journal publication. In the UK, the FCA's safeguarding Supplementary Regime went live on 7 May 2026, bringing daily reconciliations, resolution packs and a monthly safeguarding return whose first filing falls on 21 July 2026. Any group holding both a UK and an EU e-money licence now runs two reform programmes on two clocks.
What H2 will decide
Four dates frame the second half: the UK gateway opening on 30 September 2026, South Korea's tightened regime from 20 August 2026, the PSR's application clock starting when the texts reach the Official Journal, and the first UK safeguarding audit cycle completing. The EU transition is over; the sorting of who holds which licence, and at what ongoing cost, has just begun.
Method
Every figure above comes from LicenceMap's verified matrix, which tracks 52 crypto and 37 e-money licensing regimes with a dated primary source on each cell, re-verified on a rolling cycle. Authorisation counts are as of their stated dates and move weekly; the live matrix carries the current figures. Sources include national regulators (BaFin, AMF, MFSA, Central Bank of Ireland, Bank of Lithuania, FCA, HKMA, SFC, MAS, VARA), the ESMA MiCA register and peer-review publications, and official legislative texts (SI 2026/102, PSD3/PSR final texts, Act No. 21358, the GENIUS Act).
This report is informational only and is not legal advice. Verify with qualified counsel before acting.