By Darlyn Ho | Edited by Mark Walker
One hundred days have elapsed since the European Union’s Markets in Crypto-Assets (MiCA) regulation fully concluded its transitional period on July 1, 2026. As the dust settles on the most ambitious digital asset regulatory framework in history, the market is undergoing a profound structural metamorphosis. A collaborative, multi-contributor market review—spearheaded by Finery Markets and featuring insights from Banking Circle, Fipto, The Vault, and Sumsub—has provided the first granular, data-backed assessment of how MiCA is dictating the future of trading, stablecoin issuance, custody, and compliance across the continent.
By analyzing more than 16 million institutional spot crypto trades executed on Finery Markets’ infrastructure during the first nine months of 2026, compared to the same period in 2025, the report reveals that MiCA is not merely a compliance hurdle; it is a catalyst for institutionalization, market consolidation, and a fundamental shift in liquidity patterns.
The New Market Reality: A Divergence of Venues
The most striking headline to emerge from the post-MiCA landscape is the widening chasm between institutional over-the-counter (OTC) venues and traditional centralized exchanges (CEXs).
While the broader crypto market has faced volatility, Finery Markets recorded a robust 57% year-on-year growth in OTC spot volume for the nine months ending September 2026. Conversely, the top-20 centralized exchanges experienced a 47% contraction, and top-20 decentralized exchanges (DEXs) saw a 35% decline over the same duration. Notably, this divergence was consistent; OTC volumes trended upward in every month of 2026, whereas centralized exchange volumes suffered consecutive year-on-year declines throughout the period.
The Institutional Shift
Sergey Klinkov, Managing Director of Finery Markets, suggests this trend mirrors the historical evolution of foreign exchange (FX) markets. Large-block institutional flows are increasingly gravitating toward OTC rails. This preference is driven by the need for execution discretion, reduced market impact, and greater capital efficiency.
Klinkov draws a direct parallel to the implementation of MiFID II in the traditional financial sector. Just as MiFID II concentrated equities and fixed-income execution into institutional-grade infrastructure while squeezing sub-scale brokers out of the market due to mounting compliance costs, MiCA is expected to produce a similar consolidation in crypto. Smaller, non-compliant operators are finding the cost of entry prohibitive, forcing a wave of mergers, acquisitions, or market exits.
Asset Composition and the Rise of Ethereum
Beyond the venue migration, the actual composition of assets being traded has shifted significantly. In the non-stablecoin category, Ethereum has emerged as the dominant force. Ethereum’s share of non-stablecoin volume surged from 23% in the first nine months of 2025 to 50% in 2026—a 222% increase in absolute volume. Meanwhile, Bitcoin—the traditional king of the market—saw its share drop from 48% to 29%, with its absolute volume declining by 13%. This shift indicates that institutional portfolios are becoming increasingly diversified, prioritizing smart-contract-capable assets that underpin the emerging decentralized finance (DeFi) ecosystem.
Euro Stablecoins: Small Base, Massive Potential
Stablecoins now account for a staggering 83% of all trades on the Finery Markets platform, with total stablecoin volume up 76% year-on-year. While dollar-linked stablecoins remain the dominant liquidity source—maintaining a supply of roughly $299 billion, which has remained largely flat—euro-linked stablecoins are the fastest-growing, albeit smaller, segment.
EURC volume on the Finery platform rose 46-fold year-on-year. While this still represents a modest 0.12% of total stablecoin client flows, the trend is undeniable. On-chain, the supply of euro-stablecoins reached $848 million by early September 2026, marking a 22.6% increase from the $692 million reported at the start of the year.
Patrick Mollard, CEO of Fipto, argues that this growth is not merely a displacement of dollar liquidity but a structural shift. He observes that demand for euro-denominated stablecoins is being driven by international payment companies in Canada, Africa, and the Asia-Pacific region. These entities require a regulated euro leg that they can hold, redeem at par, and reconcile under European accounting standards. Furthermore, Mollard highlights that firms which missed the July 1 Crypto-Asset Service Provider (CASP) authorisation deadline have not abandoned the EU; instead, they are pivoting toward partnerships with licensed CASPs, outsourcing the regulatory burden to compliant entities.
Compliance Friction and the "Double Test" Burden
Despite the benefits of regulation, the implementation phase has introduced significant friction. Ida Mokhtassi, Head of Legal at Banking Circle, identifies the European Banking Authority’s (EBA) "double test" on reserve concentration as a major hurdle for stablecoin issuers.
Under the current framework, if an issuer places €1 billion of reserves with smaller credit institutions, they face a 5% cap per bank, necessitating at least 20 separate banking relationships. When combined with the 1.5% total-assets test, the requirements become increasingly restrictive. Banking Circle argues that these concentration limits should be calibrated to the quality of the safeguard rather than the arbitrary size of the bank. "Reserves held in a bankruptcy-remote structure are protected whatever the size of the bank holding them," Mokhtassi notes, advocating for a shift toward focusing on ring-fenced, readily available liquidity.
The Fraud Challenge
Compliance operations have also faced new, sophisticated threats. Egor Larichkin, Legal Counsel at Sumsub, notes that EU crypto verifications dropped by nearly 13% quarter-on-quarter following the MiCA deadline, with particularly sharp contractions in Germany and Belgium.
Simultaneously, the rate of rejected applications due to fraud attempts rose by almost 50%—more than double the increase observed in other regions. Larichkin attributes this spike to fraudsters weaponizing the transition period. As users were forced to migrate to new, MiCA-compliant legal entities, bad actors launched fake re-verification requests, exploiting the confusion to harvest sensitive data and credentials.
Regulatory Interplay: The PSD2/PSD3 Nexus
The first hundred days of MiCA have highlighted that regulation does not exist in a vacuum. MiCA interacts directly with the Payment Services Directive (PSD2), creating overlapping authorisation requirements for e-money token transfers.
Artem Stopnevich, CEO of The Vault, warns that a MiCA licence alone is insufficient to cover the full spectrum of activities required for a comprehensive payment service. The resolution of these regulatory overlaps—whether through new EBA guidance or a future PSD3 review—will define the ease with which stablecoin payment rails integrate into existing banking infrastructure. For now, the prevailing commercial strategy is one of partnership rather than attempting to secure parallel licences, as firms prioritize speed to market and operational stability.
Conclusion: The Path Forward
The first 100 days of MiCA have served as a stress test for the European digital asset market. While the regulation has undoubtedly increased the barrier to entry and created operational challenges for both issuers and trading venues, it has also provided the regulatory certainty necessary for large-scale institutional adoption.
The shift toward OTC, the growing prominence of Ethereum, and the nascent expansion of the euro-stablecoin market suggest that Europe is successfully positioning itself as a hub for compliant, high-integrity digital finance. However, as noted by the contributors to this review, the long-term success of MiCA will depend on the regulator’s ability to refine the "double test," address the overlaps with payment legislation, and provide clear guidance to combat the fraud patterns that have emerged during the transition.
As the industry moves beyond this initial post-MiCA milestone, the message is clear: the era of the "wild west" in European crypto is officially over. In its place, a more mature, institutional-grade ecosystem is beginning to take root—one where compliance, partnership, and structural efficiency are the new prerequisites for success.
