One hundred days after the shut of MiCA’s transitional interval on 1 July 2026, a multi-contributor market evaluation printed by Finery Markets, alongside Banking Circle, Fipto, The Vault and Sumsub, units out how the regulation is reshaping digital asset buying and selling, stablecoin issuance, custody and compliance throughout the EU.
The report attracts on greater than 16 million institutional spot crypto trades executed on Finery Markets’ platform within the first 9 months of 2026, in contrast with the identical interval of 2025.
OTC diverges from alternate markets
The headline buying and selling discovering is a pointy cut up between institutional OTC venues and centralised exchanges. Finery Markets’ OTC spot quantity grew 57% 12 months on 12 months within the 9 months to September 2026, whereas the top-20 centralised exchanges contracted 47% and the top-20 decentralised exchanges fell 35% over the identical interval. OTC quantity grew in each month of 2026; centralised alternate quantity was down 12 months on 12 months in each month.
Finery Markets managing director Sergey Klinkov attributes the divergence to structural elements acquainted from the evolution of FX markets: large-block institutional move gravitates to OTC rails for execution discretion, decrease market impression and capital effectivity. The analogy the agency attracts is to MiFID II, which concentrated equities and fixed-income execution in institutional-grade infrastructure as compliance prices squeezed sub-scale brokers out of the market. Klinkov expects MiCA to supply the same consolidation in crypto, pushing smaller operators to merge or exit.
Within non-stablecoin OTC move, the composition shifted markedly. Ethereum’s share of non-stablecoin quantity rose from 23% within the first 9 months of 2025 to 50% in the identical interval of 2026, a 222% improve in absolute quantity phrases, whereas Bitcoin’s share fell from 48% to 29% and its quantity declined 13%.
Euro stablecoin provide grows from a small base
Stablecoins accounted for 83% of trades on the Finery Markets platform, with stablecoin quantity up 76% 12 months on 12 months. Euro-linked stablecoins are the fastest-growing section, although absolutely the scale stays modest. EURC quantity on the platform rose 46-fold 12 months on 12 months, but nonetheless represents solely 0.12% of stablecoin consumer flows. On-chain, euro-stablecoin provide reached $848 million by early September 2026, up 22.6% from $692 million at the beginning of the 12 months, in line with Token Terminal. Dollar-linked stablecoin provide, by comparability, stood at roughly $299 billion, broadly flat over the identical interval.
Fipto chief govt Patrick Mollard frames the provision progress as a structural shift quite than a displacement of greenback liquidity. He notes {that a} rising share of demand for euro-denominated stablecoins is coming from fee corporations in Canada, Africa and Asia-Pacific searching for a regulated euro leg they’ll maintain, redeem at par and reconcile beneath European guidelines. He additionally observes that many companies that missed the 1 July CASP authorisation deadline haven’t left the market; the compliant path has been to companion with a licensed CASP that carries the regulatory accountability.
Reserve caps and compliance friction
Banking Circle head of authorized Ida Mokhtassi highlights the EBA’s “double test” on reserve focus as a sensible burden for issuers. Under present guidelines, a stablecoin issuer putting €1 billion of reserves with smaller credit score establishments faces a 5% cap per financial institution, requiring at least 20 banking relationships; the 1.5% total-assets take a look at tightens that additional. Banking Circle’s place is that the focus limits must be calibrated to the standard of the safeguard quite than the dimensions of the financial institution. “Reserves held in a bankruptcy-remote structure are protected whatever the size of the bank holding them,” Mokhtassi writes, arguing the double take a look at shouldn’t apply the place ring-fenced, available liquidity instantly addresses the EBA’s concern.
Sumsub authorized counsel Egor Larichkin provides a compliance operations be aware: EU crypto verifications fell by virtually 13% quarter on quarter following the deadline, with sharp contractions in Germany and Belgium. Simultaneously, the share of EU crypto candidates rejected for fraud makes an attempt rose by virtually half, greater than twice the rise seen elsewhere. Larichkin attributes this to fraudsters exploiting platform re-onboarding processes, concentrating on customers confused by migration to new authorized entities with faux re-verification requests.
Regulatory read-across
MiCA’s first hundred days sit inside a broader EU regulatory stack. PSD2 creates overlapping authorisation necessities for e-money token transfers, and The Vault chief govt Artem Stopnevich notes {that a} MiCA licence alone doesn’t cowl each exercise wanted to function an entire fee service. The decision to that overlap, whether or not by means of EBA steering or focused legislative refinement beneath any future PSD3 evaluation, will decide how easily stablecoin fee rails connect with present fee establishment infrastructure. For now, the industrial incentive runs towards partnership quite than parallel licensing.
AI degree 1 of 5: written by Darlyn Ho; AI helped with tone, construction or wording; edited and signed off by Mark Walker, Editorial Director. What the levels mean
