MiCAR and the new geography of crypto in Italy: a market reshaped by regulation
The European MiCAR Regulation (EU 2023/1114) has delivered far more than a technical adjustment or a routine regulatory update for Italy. Since coming into force, it has profoundly reshaped the structure of the crypto-asset market, redefining its boundaries and imposing a radical transformation. The outcome is already evident: a sharp and immediate contraction in the number of active operators, with consequences that go well beyond a natural market consolidation.
The shift from a registration-based system to one centred on authorisation has marked a genuine change of paradigm. MiCAR has not simply raised the bar; it has rewritten the conditions for market access, introducing capital, organisational and governance requirements aligned with those of traditionally regulated financial intermediaries. In this context, the selection process has been neither gradual nor organic, but regulatory and abrupt.
From numerical expansion to sudden contraction
As of 30 December 2025, the final deadline for submitting applications for authorisation as Crypto-Asset Service Providers (CASPs), the Italian crypto market already appears significantly downsized. Only a few months earlier, at the end of June 2025, the register of Virtual Asset Service Providers listed 138 operators. Today, according to data from the OAM register, just over 30 entities remain formally authorised to operate.
This authorisation, however, is purely transitional in nature. It remains valid only until 30 June 2026 and is conditional upon the timely submission of a MiCAR application. It does not constitute full regulatory approval, but rather a temporary allowance designed to facilitate alignment with the new European framework.
The numerical collapse cannot be attributed to mergers, acquisitions, or ordinary market cycles. It is the direct consequence of MiCAR’s entry into force, which has replaced the former national regime based on relatively light administrative registration. Many operators, although formally registered, were structurally unprepared to undertake a complex and demanding authorisation process.
A regulatory selection, not a market downturn
The contraction of the market must be understood for what it truly represents: a forced selection imposed by regulation. MiCAR has placed operators before a binary choice. Either embark on the authorisation pathway as a CASP or exit the regulated market entirely. In many cases, withdrawal was not a strategic decision, but an inevitable outcome driven by the absence of minimum structural requirements necessary to operate under harmonised supervision.
The new European framework has exposed a structural weakness that already existed beneath the surface. The Italian crypto market appeared numerically extensive but normatively fragile. Previous rules allowed the operation of entities that were formally registered yet often lacked organisational frameworks comparable to those expected of traditional financial institutions.
No Italian licences in the European CASP register
The most critical issue emerges at the European level. The official ESMA register of authorised CASPs currently lists no Italian operators. Out of more than 130 entities authorised across various Member States, none are supervised by Consob or the Bank of Italy.
Other countries have advanced more swiftly. Germany, France, the Netherlands, Spain, Austria, Malta, Cyprus and Ireland have already issued MiCAR licences, establishing an initial core of fully authorised operators. Italy, by contrast, remains without any domestic licences, with market activity sustained solely by the transitional regime.
This absence does not concern only Italian firms. Several major international players, despite publicly stating that they are engaged in the authorisation process, are still missing from the ESMA register. The broader environment, therefore, remains suspended and uncertain, with operational continuity beyond June 2026 far from assured.
The transitional regime is not a safeguard
One point requires particular clarity. Continued inclusion in the OAM register does not amount to MiCAR authorisation. It is a temporary tolerance, not a regulatory licence. Once the transitional period expires, operating without authorisation would expose firms to the concrete risk of unauthorised provision of regulated services, with significant legal and sanctioning consequences.
The implications extend well beyond operators themselves. Users and investors are equally affected. Engaging with unauthorised providers means forfeiting the protections introduced by MiCAR, facing weaker legal remedies and reduced safeguards in the event of disputes or intermediary default.
A market redesigned by regulation
What emerges is a transition imposed rather than accompanied by a gradual adjustment phase. MiCAR has reshaped the market through regulation: narrowing its perimeter, raising compliance standards and determining who is able to remain active. In the medium term, consistent implementation of the regulation may become a competitive advantage for well-structured operators and traditional intermediaries entering the sector.
In the short term, however, one fact remains unequivocal. The Italian crypto market has shrunk from 138 operators to just over 30, without a single national licence issued. The stabilisation phase is far from complete, and the market perimeter is likely to contract even further.
This article was first published in Italian on 7 January 2026.
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