EU Crypto Enforcement Risk Varies Sharply by Country
Providers serving EU clients should verify MiCA authorization, since national regulators are filing unlicensed firms at very different rates.
Updated on Nov. 4, 2026 in Financial Services
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Italy's market regulator filed 179 of the 188 entries on the European Union's register of unlicensed crypto firms, while Germany's financial supervisor filed none. The register, kept by the European Securities and Markets Authority under the Markets in Crypto-Assets Regulation (MiCA), matters most to crypto and financial-service providers operating across EU borders, since the law's transition period for unlicensed providers ended on July 1.
Why it matters
The register is the only EU-wide public record of firms that national supervisors say serve clients without authorization, so it signals where enforcement attention is concentrated. The uneven filing pattern shows that the file reflects what each national authority chooses to report rather than a complete picture of unlicensed activity across the bloc.
Italy's CONSOB had blocked 1,861 internet sites as of October 29, 250 of them tied to crypto-assets, and BaFin in Germany published 245 consumer warnings in 2026 through November 3, 89 of which mention crypto services. The France-based AMF added 64 crypto names to its blacklist since January.
The players
European Securities and Markets Authority (ESMA)
The EU financial markets regulator that maintains the register of unlicensed crypto firms under MiCA and supervises the largest providers across the bloc.
CONSOB
Italy's securities market regulator, which has ordered internet providers to block unauthorized financial websites since 2019 and has filed most entries on the register.
BaFin
Germany's federal financial supervisor, which issues consumer warnings and oversees the largest population of authorized crypto providers in the EU.
Autorité des marchés financiers (AMF)
France's financial markets regulator, which maintains a blacklist of unauthorized firms and added 64 crypto names to it this year.
The details
Under MiCA, a crypto firm serving EU clients needs authorization from a national regulator, and ESMA's register lists firms that supervisors say operate without it. Italy's CONSOB has ordered internet providers to block unauthorized financial websites since 2019, a practice that has produced the largest share of entries on the file. The register's non-exhaustive design means entries depend on each national authority's reporting, which helps explain why countries with large licensed-provider populations can file none.
Timeline
July 1: MiCA's transition period for unlicensed providers ended.
October 9: EU finance ministers limited direct ESMA supervision to the largest providers.
October 29: The ESMA file was reviewed, and CONSOB's blocked-site tally reached 1,861.
November 4: FM Intelligence published its analysis of the register.
June 30, 2027: The European Commission is due to report on MiCA.
Market Landscape
The register emerges under MiCA, the EU's first comprehensive crypto licensing regime, which replaced a patchwork of national rules and sets a single authorization requirement for providers serving EU clients. Its uneven national filing pattern contrasts with the EU-wide harmonization MiCA was designed to create.
Crypto providers serving EU clients should confirm whether they hold the required authorization, since national regulators are actively blocking and listing unauthorized firms. Compliance and licensing questions should be routed to qualified counsel familiar with MiCA.
The takeaway
Enforcement intensity under MiCA varies sharply by country, so a provider's risk depends on where its clients are and which national regulator is most active. Operators should track the Commission's 2027 MiCA report as a signal of whether the register and enforcement pattern will be standardized.
What happens next
The European Commission is due to report on MiCA by June 30, 2027, which will assess how the regime has worked since the transition period ended.
Further reading
For background on how these rules are applied across industries, see the Financial Services section.
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