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EEA Tracker · October 2026

EEA Regulated-Fintech Tracker

This edition covers July to early October 2026. The ESMA Interim MiCA Register listed 362 authorised CASPs on 30 September, against the roughly 210 cited in the July snapshot, and the mix is shifting: 144 of the 362 are traditional-finance firms and 218 are crypto-native. Register analysis reported in September put banks' MiCA-listed footprint at about 80 providers, roughly double its level in late June, and about 23% of the register. Germany leads with 96 authorisations, ahead of France (36) and the Netherlands (29). On stablecoins, 22 e-money token issuers were authorised as of 8 August and no asset-referenced token issuer had been authorised as of 1 September. Post-deadline supervision so far has been warnings rather than headline sanctions: the CSSF (2 July) and AMF (8 July) warned about unauthorised providers and misuse of the reverse-solicitation exemption, and BaFin published twelve unauthorised-business notices between 2 and 11 September, five of them naming crypto-asset services. On 1 October AMLA finalised its first three regulatory technical standards (customer due diligence, business relationships and linked transactions, and group-wide arrangements) and sent them to the European Commission; they apply six months after Official Journal publication. The EBA responded to the Commission's MiCA review consultation on 24 September. PSD3 and PSR remain pending formal adoption and publication in the sources we checked. EMI and PI counts and the banking-access panel are carried forward from the July review and were not refreshed for this edition.

Snapshot 2026-10 · published 2026-10-06 · methodology

Practitioner layer

Where's the door open this month?

Per-jurisdiction temperature read on banking-access reality for foreign-controlled regulated fintechs. Tier-archetype framing — finconduit does not name specific banks per its published constraint.

Tier acceptance posture
Selective

Tier 1 — EU clearing

Post-1-July, Tier-1 EU clearing serves authorised CASPs only. A granted CASP licence (or credit-institution / EMI authorisation for issuers) is the hard precondition — no authorisation, no Tier-1 account. Onboarding cycles 16–26 weeks once the licence is in hand.

Open

Tier 2 — Specialist

Tier-2 specialist EEA banks and EMI-as-correspondent partners are the working layer for authorised CASPs, and for firms repositioning their EU structure post-deadline. Pricing has firmed. Onboarding 6–14 weeks; AML / TM programme depth is the binding constraint.

Open

Tier 3 — Crypto-aware

Tier-3 crypto-aware correspondents continue to onboard at scale, including non-EEA-facing firms that exited the EU perimeter but still need rails elsewhere. Sanctions-screening and KYT depth remain the binding constraints. Onboarding 4–10 weeks.

Jurisdiction temperature

Germany

Stable
Selective

Tier-1 EU clearing serves authorised CASPs only: a granted licence is now the hard gate, not a nice-to-have. BaFin continues to publish consumer notices against unauthorised crypto providers.

Netherlands

Stable
Selective

AFM-authorised CASPs retain workable Tier-1 access. With the perimeter now clean, banking onboarding is a function of the authorisation itself; the transitional ambiguity is gone.

France

Stable
Open

France remains the most workable Tier-1 banking corridor for authorised crypto activity. AMF paired an open authorisation pathway with a post-deadline enforcement sweep against the unauthorised.

Ireland

Improving
Selective

English-speaking corridor workable for authorised US-headquartered groups. Several large exchanges chose Ireland as their EU authorisation base, anchoring Tier-1 relationships there.

Lithuania

Stable
Constrained

The EEA's deepest EMI/PI hub (82 EMIs / 45 PIs) still has the banking layer as its binding constraint. Authorised CASPs route through Tier-2 specialist partners; Tier-1 correspondent reach has not recovered.

Estonia

Stable
Constrained

Post-2022 cleansing residue persists; the deadline thinned the local VASP population further as unconverted firms ceased. FI authorisation still does not translate automatically into euro IBANs.

Luxembourg

Stable
Selective

Strong private + institutional banking; Tier-2 specialist partners onboard authorised firms with mature AML programmes. CSSF Circular 26/906 governance-alignment continues to raise the substance bar.

Malta

Stable
Constrained

Malta now has 25 authorised CASPs. Post-Moneyval drag persists; Tier-2 specialist banking via EU correspondents typical, local Tier-1 access narrow.

Cyprus

Stable
Constrained

CySEC has authorised 24 CASPs, one of the larger cohorts in the EEA. Banking remains the constraint: limited Cypriot correspondent reach, EMI-partner reliance the norm.

Material events — last 30 days
  • No new material banking events logged this month. The posture above is carried forward from the previous review.
Working through one of these?

We see the operating reality these tracker entries reflect — every working day.

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For orientation only — not financial, legal, regulatory, or investment advice. Outputs are directional and based on generalised inputs. Decisions should be taken only after consultation with a qualified adviser on your specific facts — book the full assessment before acting on anything you read here.

Numbers shown exclude finconduit fees and any third-party costs (legal, audit, regulator-mandated experts, banking-relationship fees, document-translation, ongoing supervisory levies, or local agent / service-provider charges). Real-world authorisation budgets typically exceed the headline regulator-side numbers by a meaningful multiple.