Two of the largest cryptocurrency firms are close to securing EU-wide licenses under the bloc’s new Markets in Crypto-Assets (MiCA) regulation, sources say, even as regulatory disagreements grow over how quickly and rigorously some member states are approving crypto companies.
MiCA, which came into force earlier this year, allows EU countries to issue licenses enabling crypto firms to operate across all 27 member states. However, concerns have emerged behind closed doors about the speed and standards of some approvals—particularly those from smaller regulators like Malta.
Gemini, the crypto trading platform founded by billionaire Winklevoss twins Tyler and Cameron, is reportedly on the brink of receiving a Maltese license. Malta has previously granted licenses to crypto firms such as OKX and Crypto.com shortly after MiCA’s introduction, drawing criticism from regulators in countries like France, where the financial regulator AMF warned of a potential “regulatory race to the bottom.”
Other EU regulators have voiced concern that smaller authorities with fewer staff, like Malta’s, may not have sufficient resources to rigorously enforce rules. The European Securities and Markets Authority (ESMA) is reviewing Malta’s licensing process and is expected to release a report soon.
The Malta Financial Services Authority defended its fast approvals, citing years of experience and strict anti-money laundering standards. OKX also described its licensing as “rigorous” and compliance-focused.
Meanwhile, Luxembourg is expected to grant a license to Coinbase, the first U.S. crypto company in the S&P 500, though the company’s European operation in Luxembourg is relatively small. Luxembourg’s financial regulator has declined comment, but insiders reject accusations of laxity, suggesting some criticism is driven by competition among member states to attract crypto businesses.
Coinbase’s pending approval represents a setback for Ireland, where skepticism toward crypto has grown, with the Irish Central Bank Governor calling it akin to a Ponzi scheme in 2023.
The global crypto market, currently valued around $3.3 trillion, has endured volatility including the 2022 collapse of major U.S. exchange FTX. The EU continues to struggle with regulatory divergence among member states, while discussions are ongoing about granting ESMA more direct authority over crypto oversight.
ESMA’s head, Verena Ross, has advocated publicly for enhanced powers, but some EU countries remain cautious.