One hundred days after the close of MiCA’s transitional period on 1 July 2026, a multi-contributor market review published by Finery Markets, alongside Banking Circle, Fipto, The Vault and Sumsub, sets out how the regulation is reshaping digital asset trading, stablecoin issuance, custody and compliance across the EU.

The report draws on more than 16 million institutional spot crypto trades executed on Finery Markets’ platform in the first nine months of 2026, compared with the same period of 2025.

OTC diverges from exchange markets

The headline trading finding is a sharp split between institutional OTC venues and centralised exchanges. Finery Markets’ OTC spot volume grew 57% year on year in the nine months to September 2026, while the top-20 centralised exchanges contracted 47% and the top-20 decentralised exchanges fell 35% over the same period. OTC volume grew in every month of 2026; centralised exchange volume was down year on year in every month.

Finery Markets managing director Sergey Klinkov attributes the divergence to structural factors familiar from the evolution of FX markets: large-block institutional flow gravitates to OTC rails for execution discretion, lower market impact and capital efficiency. The analogy the firm draws is to MiFID II, which concentrated equities and fixed-income execution in institutional-grade infrastructure as compliance costs squeezed sub-scale brokers out of the market. Klinkov expects MiCA to produce a similar consolidation in crypto, pushing smaller operators to merge or exit.

Within non-stablecoin OTC flow, the composition shifted markedly. Ethereum’s share of non-stablecoin volume rose from 23% in the first nine months of 2025 to 50% in the same period of 2026, a 222% increase in absolute volume terms, while Bitcoin’s share fell from 48% to 29% and its volume declined 13%.

Euro stablecoin supply grows from a small base

Stablecoins accounted for 83% of trades on the Finery Markets platform, with stablecoin volume up 76% year on year. Euro-linked stablecoins are the fastest-growing segment, though the absolute scale remains modest. EURC volume on the platform rose 46-fold year on year, yet still represents only 0.12% of stablecoin client flows. On-chain, euro-stablecoin supply reached $848 million by early September 2026, up 22.6% from $692 million at the start of the year, according to Token Terminal. Dollar-linked stablecoin supply, by comparison, stood at roughly $299 billion, broadly flat over the same period.

Fipto chief executive Patrick Mollard frames the supply growth as a structural shift rather than a displacement of dollar liquidity. He notes that a growing share of demand for euro-denominated stablecoins is coming from payment companies in Canada, Africa and Asia-Pacific seeking a regulated euro leg they can hold, redeem at par and reconcile under European rules. He also observes that many firms that missed the 1 July CASP authorisation deadline have not left the market; the compliant path has been to partner with a licensed CASP that carries the regulatory responsibility.

Reserve caps and compliance friction

Banking Circle head of legal Ida Mokhtassi highlights the EBA’s “double test” on reserve concentration as a practical burden for issuers. Under current rules, a stablecoin issuer placing €1 billion of reserves with smaller credit institutions faces a 5% cap per bank, requiring at least 20 banking relationships; the 1.5% total-assets test tightens that further. Banking Circle’s position is that the concentration limits should be calibrated to the quality of the safeguard rather than the size of the bank. “Reserves held in a bankruptcy-remote structure are protected whatever the size of the bank holding them,” Mokhtassi writes, arguing the double test should not apply where ring-fenced, readily available liquidity directly addresses the EBA’s concern.

Sumsub legal counsel Egor Larichkin adds a compliance operations note: EU crypto verifications fell by almost 13% quarter on quarter following the deadline, with sharp contractions in Germany and Belgium. Simultaneously, the share of EU crypto applicants rejected for fraud attempts rose by almost half, more than twice the increase seen elsewhere. Larichkin attributes this to fraudsters exploiting platform re-onboarding processes, targeting users confused by migration to new legal entities with fake re-verification requests.

Regulatory read-across

MiCA’s first hundred days sit inside a broader EU regulatory stack. PSD2 creates overlapping authorisation requirements for e-money token transfers, and The Vault chief executive Artem Stopnevich notes that a MiCA licence alone does not cover every activity needed to operate a complete payment service. The resolution to that overlap, whether through EBA guidance or targeted legislative refinement under any future PSD3 review, will determine how smoothly stablecoin payment rails connect to existing payment institution infrastructure. For now, the commercial incentive runs toward partnership rather than parallel licensing.

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