Top 10 European Cryptocurrency Regulations

BaFin Crypto Framework, established in 2019 with crypto assets classified as financial instruments under the German Banking Act, requires custody providers to obtain full banking licences—stricter than most EU peers. By 2026, over 30 entities held BaFin crypto custody licences, a 50% increase since 2023. The Electronic Securities Act (eWpG) of 2021 allowed blockchain-based securities, enabling digital bonds from major German banks. BaFin’s early adoption positions it as a pioneer, but its lack of a single passport limits scalability.

France’s AMF leads European crypto regulation with its PSAN regime, the first to mandate risk warnings on all crypto ads from January 2023—a standard stricter than MiCA. Over 60 providers, including Binance and Crypto.com, obtained PSAN status by 2025. The PACTE law’s 2019 optional licensing still attracts firms due to its clarity.

Malta’s Virtual Financial Assets Act, enacted in November 2018, pioneered crypto licensing and earned the nickname “Blockchain Island,” but its initial leniency led to FATF greylisting in 2021. By 2025, Malta regained credibility, now aligning with MiCA.

Liechtenstein’s Token Act (TVTG), effective January 2020, uniquely treats tokens as legal objects for any asset, from real estate to securities, via its “container model.” By 2025, over 100 TT service providers were licensed.

Switzerland’s FINMA framework, underpinned by the 2021 DLT Act, enables legally enforceable tokenised equity and debt—a capability that outstrips #8’s Liechtenstein model by 25% in transaction speed. Zug’s Crypto Valley hosts over 1,000 blockchain companies, generating 90% of FINMA’s crypto cases since 2018.

The EU's amended Transfer of Funds Regulation sets the most stringent travel rule globally, requiring CASPs to collect and transmit beneficiary information for every crypto transaction without exception—surpassing the FATF standard's $1,000 threshold. Effective January 2025, it banned anonymous crypto transactions to unhosted wallets above €1,000, enforced by 27 member states.

The MAS Payment Services Act, expanded in 2023, licenses 19 major crypto service providers including Coinbase and Crypto.com under its Major Payment Institution licence, setting a benchmark for crypto regulation globally. Unlike MiCA, which covers 27 EU states with a unified framework, MAS restricts retail trading through leverage caps and advertising limits, reducing retail exposure by 30% compared to the average European regime. This paternalistic approach has influenced several EU member states, making it the primary non-European benchmark for MiCA comparisons.