A regulatory quirk in the European Union’s Markets in Crypto-Assets framework has left 14 of approximately 23 authorized stablecoin issuers without the ability to offer custody services for their own tokens to corporate clients. The disclosure came from Patrick Hansen, Circle’s Director of EU Strategy and Policy, who expressed surprise at the passivity of competitors facing the restriction.
According to the interim register of the European Securities and Markets Authority (ESMA), only nine companies obtained full authorization covering both electronic money token (EMT) issuance and crypto-asset service provider (CASP) services. The rest are trapped in a regulatory gap that severely limits the range of services they can offer.
The restriction does not affect retail users, who can still move tokens between non-custodial wallets. But in the corporate segment, issuers without a CASP license cannot hold tokens in custody or process automated payments for clients. To offer those services, companies must complete an Article 60 notification procedure that can take up to one year in jurisdictions such as France or Luxembourg. Faced with that delay, several issuers have migrated to regulated third-party platforms, creating forced B2B partnerships.
A notable example is Schuman Financial, issuer of the French stablecoin EURØP. The company holds EMT status but lacks CASP authorization, so it uses the European MiCA CASP and EMI licenses of Ripple to provide legal custody and transfers across 30 European countries. Schuman Financial has integrated its asset into the XRP Ledger infrastructure.
Circle, issuer of USDC and EURC, and Société Générale-Forge are positioned as the biggest beneficiaries of this fragmentation. Both hold dual regulatory authorization that competitors may take months or even a year to obtain, giving them a structural advantage in capturing institutional capital within the European Economic Area.
Separately, the latest ESMA MiCA register, dated 12 August 2026, contains 329 records covering about 325 named entities. Hedera Chief Policy Officer Nilmini Rubin had cited 244 approvals from a universe of more than 1,200 legacy EU crypto firms, but that figure was already superseded when 37 more entries appeared after the transition ended. Even 325 names represent only about 27% of the 1,200-plus baseline.
The register combines Article 63 authorisations for crypto-asset service providers with Article 60 notifications from banks, investment firms and other already-regulated financial entities, and it also contains some repeated legal entities. Germany’s BaFin leads with 73 records, followed by France’s AMF with 35, the Netherlands’ AFM with 29, Cyprus’ CySEC with 26, and Malta’s MFSA with 22. Those five supervisors account for 185 of the 329 records, while Greece, Hungary, Poland and Romania have no home-state entry in the file.
The transitional runway for previously registered providers closed on 1 July 2026. France’s AMF had instructed unsuccessful applicants to prepare an orderly exit, and a pending application is not permission to operate. For clients and brokers, the message is clear: a familiar brand is no substitute for checking the regulated legal entity in ESMA’s register and confirming the specific authorised services, custody arrangements and passport notifications before onboarding EU clients.
