Germany Leads EU in MiCA Licenses — But Crypto Startups Are Leaving

Germany leads the EU in MiCA licenses issued. It has the most Bitcoin nodes of any European country.

Major banks, including Deutsche Bank, DZ Bank, and Commerzbank, have all entered the crypto space under the new regulatory framework.

The Official Picture vs. Ground Reality

On paper, the numbers look strong. However, practitioners closest to the industry see a different reality. Despite official success metrics, activity and talent are flowing toward other European jurisdictions.

The gap between what the statistics show and what is happening on the ground reveals a structural challenge that threatens long-term hub status.

Over 30 crypto licenses have been granted, more than almost any other EU country. Luxembourg approved only three.

On paper, Germany is winning decisively. Yet most of these licenses went to traditional banks offering limited services. The startups and crypto-native companies building the next generation of digital asset infrastructure are licensing elsewhere and passporting services back into Germany.

Germany added 16 new MiCA-licensed institutions in Q4 2025, but this number masks a concerning trend. Most are traditional banks offering only a single service such as order execution or transfer. That narrowing of scope raises questions about what kind of crypto market Germany is actually building, one dominated by established institutions rather than innovation.

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Berlin and Frankfurt Are Losing Ground

At the BeInCrypto expert council on MiCA and crypto regulation, Matthias Steger, a crypto tax advisor who has engaged directly with Germany’s Federal Ministry of Finance on digital asset regulation, was blunt about the situation.

“We lost our big hubs in Berlin and in Frankfurt,” Steger said. “And I think that’s not depending on MiCA itself. It’s depending on how we Germans use and work with the MiCA rules.”

This statement captures the core problem. Germany is applying MiCA rules more strictly than almost any other EU country. That gap is pushing companies toward Vienna, Lisbon, and other jurisdictions that move faster and ask less.

Being pro-crypto in rhetoric while applying the most demanding regulatory interpretation in the EU creates a mismatch that companies resolve by relocating.

MiCA came into full force across the EU in December 2024. Most EU countries kept the full 18-month transition window. Germany shortened it to 12 months, setting a hard deadline of December 31, 2025, for all crypto-asset service providers to complete the switch to CASP authorization under BaFin. This aggressive timeline compounds the pressure on companies already struggling with compliance costs.

Vienna Emerges as the Real Hub

Austria’s Financial Market Authority has positioned itself as one of the EU’s most accessible MiCA licensing authorities. The competitive advantage is clear: efficient licensing timelines under six months compared to Germany’s longer processes. Vienna’s regulatory environment offers clarity without the bureaucratic weight that companies experience in Germany.

The results are visible and significant. Bybit established its European headquarters in Vienna after securing its MiCA license from the FMA and has announced plans to hire over 100 staff.

KuCoin chose Austria for its EU regulatory base. AMINA, the Swiss digital asset bank, selected Vienna over Frankfurt or Berlin, a particularly notable choice given Germany’s institutional strength.

Steger acknowledged the broader shift:

“We have it very perfect in Austria. We have it very perfect in Portugal. There are really spots like Germany that are pro crypto.” The framing matters. Germany remains described as pro-crypto. However, sentiment divorced from execution creates opportunities for competitors.

Steger’s recommendation was direct:

“I would ask the BaFin to lower it. MiCA should be the lowest level we have at all, not the highest level like the Germans think.”

This reflects a consensus among industry practitioners. Germany has the infrastructure, the institutional base, and the regulatory credibility. It has the most Bitcoin nodes in Europe. It has the banking relationships and financial expertise. Whether it keeps the companies that build on that foundation is a different question entirely.

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