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EEA Tracker · July 2026

EEA Regulated-Fintech Tracker

The MiCA grandfathering transitional period ended on 1 July 2026, and the aftermath is stark. Of the 1,200+ firms that previously held national VASP registrations across the EEA, only ~210 hold full CASP authorisation — roughly 83% did not convert: they ceased EU services, stayed mid-application without legal standing, or withdrew from the market. Several major global exchanges suspended or withdrew EU-facing services from 1 July. NCAs have moved to enforcement, with ESMA coordinating a harmonised application across the 27 member states and France's AMF running a targeted sweep against unlicensed operators. The perimeter is now clean: after 1 July, serving EU clients without a CASP authorisation is a breach of EU law, full stop. Attention shifts to AMLA, which must submit its first tranche of ~23 RTS / ITS / guidelines to the European Commission by 10 July 2026 — the operational detail of the AMLR that applies from 10 July 2027. Banking access has completed its flight-to-authorised-status: Tier-1 now serves authorised CASPs only.

Snapshot 2026-07 · published 2026-07-06 · 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

→
Selective

Post-deadline, Tier-1 EU clearing serves authorised CASPs only — a granted licence is now the hard gate, not a nice-to-have. Unauthorised firms have exited or moved offshore. BaFin is actively blocking access to unauthorised offshore exchanges serving German users.

Netherlands

→
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

→
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

↗
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

→
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

→
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

→
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

→
Constrained

MFSA cleared a cluster of final authorisations into the deadline. Post-Moneyval drag persists; Tier-2 specialist banking via EU correspondents typical, local Tier-1 access narrow.

Cyprus

→
Constrained

CySEC finished clearing its application backlog (14 CASPs authorised). Banking remains the constraint: limited Cypriot correspondent reach, EMI-partner reliance the norm.

Material events — last 30 days
  • 2026-07-02
    tier1 tightening

    With the perimeter clean post-1-July, Tier-1 EU clearing banks formalised "granted CASP authorisation" as a hard onboarding precondition for crypto activity. Pending applications no longer progress banking files in parallel — the licence must land first.

  • 2026-07-01
    nca derisking statement

    NCAs signalled that a granted authorisation removes the de-risking rationale for authorised CASPs — but banks have simultaneously exited relationships with firms that failed to convert by the deadline.

  • 2026-06-28
    tier2 entry

    Tier-2 specialist partners expanded capacity to absorb firms repositioning their EU structure post-deadline, prioritising those with a granted authorisation or a credible relocation plan into an authorised EEA entity.

  • 2026-06-25
    correspondent policy shift

    Tier-1 correspondents finalised USD-clearing policies keyed to CASP-authorisation status, cutting off unauthorised EEA-facing crypto flows as the transitional period closed.

  • 2026-06-20
    safeguarding bank change

    A specialist EEA safeguarding-bank partner moved to authorised-only onboarding for crypto-adjacent EMIs, aligning its intake to the post-deadline perimeter.

Working through one of these?

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

Authorisation in progress, banking-access pressure, an inspection finding to remediate, a regulatory deadline approaching — book a free assessment to map the right next move against your specific facts.

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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.