Gemini, the U.S.-based crypto exchange, and Coinbase, the first crypto firm listed on the S&P 500, are on the verge of securing licences to operate across the European Union (EU) under the Markets in Crypto-Assets (MiCA) regulation.
The milestone would expand the two crypto giants’ presence in the growing EU market, even as it exposes growing friction among regulators over the speed and consistency of crypto licensing.
Malta and Luxembourg take the lead
According to Reuters, Gemini is close to securing approval from Malta, which has been quick to approve crypto firms under MiCA since the regulation came into effect earlier this year.
A spokesperson for the Malta Financial Services Authority stated that four crypto licences have been granted so far and that the country’s experience with supervising crypto companies contributed to the rapid approvals.
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“Expedited processing was due to its in-depth understanding acquired over these years,” the spokesperson explained, adding that local anti-money laundering standards remain stringent.
Meanwhile, Coinbase, the first U.S.-listed crypto exchange to join the S&P 500, is expected to obtain its MiCA licence through Luxembourg.
A Coinbase spokesperson, while declining to comment on the specific licensing application, described Luxembourg as a high-bar, well-respected global financial centre, and added that the company plans to expand its Luxembourg office by hiring more than 20 people by the end of the year.
Regulatory rift within the EU
This presents a major opportunity for the two global crypto giants, as MiCA allows any license granted by a single EU member state to unlock access to all 27 countries in the bloc.
However, concerns are mounting. France’s financial regulator, the Autorité des marchés financiers (AMF), has openly cautioned that the European Securities and Markets Authority (ESMA), lacking direct licensing power, could trigger a regulatory race to the bottom, with nations competing to lure crypto firms.
The risks are substantial. While the global cryptocurrency market is now valued at roughly $3.3 trillion, past debacles—most notably the 2022 collapse of U.S. exchange FTX—have left regulators on high alert.
MiCA was introduced to bring clarity, investor protection, and market stability to the digital asset sector by harmonising rules across EU member states. Yet national authorities still retain licensing power, even as ESMA pushes for greater oversight authority.
While many in the crypto industry have welcomed MiCA’s clarity, others remain critical of specific provisions.
A central concern has been the regulation of stablecoins — cryptocurrencies pegged to stable assets, such as the U.S. dollar or the euro. One of MiCA’s more controversial clauses requires stablecoin issuers to hold a significant portion of reserves in European banks.
This rule has already impacted market behavior. Tether, issuer of the popular USDt stablecoin, has opted not to register under MiCA.
However, other issuers — including Circle, Crypto.com, Fiat Republic, and Société Générale — have successfully received approvals.
Even so, the adoption of MiCA-compliant stablecoins has been slow. Fabio Panetta, Governor of the Bank of Italy and former European Central Bank official, remarked that in Italy, MiCA has not led to significant stablecoin adoption. Instead, he observed a shift in interest toward custodial and trading services.