Ten months after the MiCA (Markets in Crypto-Assets) regulation came into force, Spain shows steady but uneven progress in building its new digital financial ecosystem. MiCA regulates cryptocurrency services in the EU, seeking legal certainty, investor protection and financial stability.
As of early November, Spain has 54 authorized cryptocurrency service providers (CASPs), of which only three are of national origin and all but one belong to the banking sector.
Banks were the first to obtain MiCA licenses for three main reasons: capital strength, regulatory experience and custody infrastructure. Entities such as BBVA, Cecabank and Openbank have taken advantage of their CNMV-supervised status to speed up the process, while the rest of the non-financial entities have to go through more complex technical and legal assessments. This difference creates an asymmetry of access: banks only notify their intention to offer crypto services, while non-financial companies must submit a complete and detailed application. The result is an operational advantage for credit institutions in the initial phase of MiCA implementation. An illustrative example is Bit2Me, which announced its intention to obtain the license months ago, but was only officially authorized in July. This time gap raises a fundamental question: does the regulatory framework make it difficult for new competitors to enter?
In any case, all entities, financial or otherwise, must ensure that natural persons who inform, advise or provide services on behalf of the cryptocurrency service provider have the necessary knowledge and skills. ESMA, Europe’s stock market regulator, has published guidelines setting out rigorous minimum training criteria: 80 hours for reporting staff and 160 hours for advisors, along with requirements for ongoing training and technical understanding of the crypto ecosystem.
In parallel, EMTs (tokens electronic money regulated by MiCA) are emerging as a key element in the European digital financial architecture. Banks such as CaixaBank have developed EMT pilot projects, anticipating the digital euro expected in 2029. stablecoins Dollar-denominated, regulated EMTs offer a way to strengthen Europe’s strategic autonomy in digital payments. This movement, in line with the vision expressed by the governor of the Bank of Spain, responds not only to a logic of innovation, but also to a geoeconomic need: Europe seeks monetary sovereignty in an environment where global cryptoassets are dominated by American actors.
Progress is structural, but not without challenges. Supervision is demanding, processes are slow and uncertainty persists over the transitional regime, which in Spain expires on 31 December 2025, after having brought forward the maximum date indicated by the European Regulation by six months. The goal: to create a stable regulatory and supervisory framework that offers legal certainty and protects investors in the provision of cryptoasset services.
For MiCA to deliver on its promise of European financial integration, greater regulatory clarity, a practical approach and targeted public-private collaboration will be needed. We at AFI conclude that MiCA represents a historic opportunity for Europe, but its success will depend on how the tension between regulatory ambition and competitive dynamism is managed.
