Broker and order routing
The cheapest way into the regime on paper, and the model whose European numbers are the most distorted. Both of those facts are worth understanding before you use either one.
Two services, and the difference is who touches the order
Execution of orders on behalf of clients means you act on a client instruction to buy or sell. Reception and transmission of orders for crypto-assets on behalf of clients means you take the order and hand it to somebody else who does. Both are class 1 services with a floor of €50,000, the lowest in the regulation.
Firms often name both, and that is usually right: you route most flow to a liquidity provider and fill some of it yourself. What matters is that filling it yourself out of your own inventory is neither of these services. That is exchange, it is class 2, and the capital floor is two and a half times higher. Where that line sits.
The register says 219 and that number is a trap
Execution looks like the second most common permission in Europe. Read the composition and it stops looking like a crypto broker population at all.
Counting execution of orders overstates the number of firms that provide it as a business. Of the 387 register rows counted on 23 October 2026, 111 name exactly one service, 88 of those 111 are recorded as Article 60 notifications, and 70 of them name execution of orders alone. Germany reports 87 of the 219 rows naming execution.
ESMA, Interim MiCA register, crypto-asset service providers (CASPS.csv) (2026-10-20) · Verified on 2026-10-23 · Next review 2026-11-23
Unpack that. 111 rows on the register name exactly one service. 88 of those are Article 60 notifications, and 70 of them name execution of orders and nothing else. That is the signature of an institution that already holds a licence adding one narrow activity to it, and Germany alone accounts for 87 of the 219 execution rows.
So if you are sizing up the competitive field for a crypto brokerage, 219 is not your comparison set and neither is the German figure. The firms doing what you intend to do are a much smaller group, and they are mostly holding three or four services rather than one.
What the European register shows for this permission
- Register rows naming it
- 219 across 25 home states
- Recorded as Article 63 authorisations
- 23
- Recorded as Article 60 notifications
- 94
- No legal basis recorded
- 102
- Held in Lithuania
- 2
Largest home states: Germany 87, Cyprus 22, France 20, Malta 17, Netherlands 10.
Most often held alongside: providing custody and administration of crypto-assets on behalf of clients (131 of 219) , providing transfer services for crypto-assets on behalf of clients (118 of 219) , exchange of crypto-assets for funds (99 of 219) , exchange of crypto-assets for other crypto-assets (74 of 219) .
Counted from ESMA's interim register of crypto-asset service providers, file last updated 20 October 2026, counted 23 October 2026. The three basis figures do not sum to the total because the register's legal-basis column is optional and most national authorities leave it empty, Lithuania among them. Why that gap matters. Rows naming execution of orders on behalf of clients are counted, whether or not the firm also holds other permissions.
Reception and transmission, separately
102 rows name reception and transmission, with Germany and Cyprus the largest. 68 of them also name execution, which tells you the two are usually one business rather than alternative models. A firm that only ever passes orders on, touching no client asset and taking no position, is the lightest regulated footprint available under MiCA, and it is a genuinely viable starting shape for a new entrant.
What takes a broker out of class 1
One thing, and it is almost always the same thing. If a client can leave a balance with you between orders, you are holding client assets, that is custody, and custody is class 2 at €125,000. The broker who budgeted for €50,000 and designed a product with an account balance in it has already left class 1 and usually does not know yet. The custody test.
Advice is the other way out, and it is a different kind of cost. Making personal recommendations is its own class 1 service, so the floor does not move, but it brings proof that the individuals advising have the necessary knowledge and expertise (article 62(2)(q)). Proving the competence of named individuals is a hiring and documentation obligation rather than a capital one, and it is a common late surprise for firms whose support team has been answering the question what should I buy in a chat window.
What the file has to carry
Execution adds execution policy (article 62(2)(p)). It is the one extra item, and it has to be real: where you route, why you route there, how you monitor whether the client got a good outcome, and what you do when they did not. A policy that says you seek the best available result without describing the venues, the monitoring or the review will not survive a question about it. The rest of the file.
What this page could not verify
- That the single-service execution rows are banks. They are recorded as Article 60 notifications, which only an already-licensed institution can make. The inference that they are mostly credit institutions comes from the German concentration and the entity names in the register, and it is ours rather than BaFin's.
- No count of genuine crypto brokerages. The claim here is that 219 overstates it. The register does not carry a field that would let anyone produce the smaller number, and we have not estimated one.
- The register moves. Counted 23 October 2026 from a file ESMA last updated four days earlier.
Regulatory references on this page were read against the primary text on 23 October 2026. Every figure is held in the source register with the document it came from.