Italy Filed 95% of the EU's Register of Unlicensed Crypto Firms

Italy's market regulator filed 179 of the 188 entries on the EU's register of unlicensed crypto firms, according to an FM Intelligence analysis published on November 4, 2026. Authorities in four other countries supplied the remaining nine entries. The European Securities and Markets Authority (ESMA) maintains the list under the Markets in Crypto-Assets Regulation (MiCA), whose transition period ended on July 1 for providers without a license.

The register serves as the only EU-wide public record of firms that national supervisors claim serve clients without authorization. However, it primarily reflects the work of one supervisor, as evidenced by Italy's dominant contribution. Banks, payment firms, and brokers that screen counterparties against the register draw information from just five of the 30 European Economic Area (EEA) states.

Italy's Aggressive Approach

Italy's Commissione Nazionale per le Società e la Borsa (CONSOB) has ordered internet providers to black out unauthorized financial websites since 2019. By October 29, 2026, its tally reached 1,861 sites, 250 of which were tied to crypto-assets. The analysis suggests that a supervisor already naming domains in bulk may find it easier to pass them on to ESMA.

Germany's Contrasting Strategy

Germany represents the opposite end of the spectrum. ESMA lists 119 authorized or notified providers based there, the most of any member state. German supervisors have filed no entry in the non-compliant register. At home, the Federal Financial Supervisory Authority (BaFin) published 245 consumer warnings in 2026 to November 3, with 89 mentioning crypto services.

Reporting Inconsistencies

France's Autorité des marchés financiers (AMF) added 64 crypto names to its own blacklist since January 2026, while Cyprus's CySEC cited MiCA's Article 59 in its website warnings. Neither authority has an entry in the ESMA file. Belgium's Financial Services and Markets Authority filed six entries, and the Czech, Dutch, and Slovak authorities one each, leaving 25 EEA states with none.

MiCA's Article 110 describes the register as non-exhaustive, setting minimum content for entries but no duty or deadline for national authorities to submit them. Germany's zero entries are consistent with using different reporting channels rather than an absence of unlicensed crypto offers.

Supervision Debate

The reporting gap occurs alongside a separate debate over who supervises crypto firms. EU finance ministers agreed on October 9 to limit direct ESMA supervision to the largest cross-border providers, narrowing a European Commission plan to move all of them to the Paris-based authority. The ESMA file points to a second gap in where unlicensed activity is reported, and ESMA has added no entry of its own.

The full FM Intelligence analysis examines what the 188 entries contain and projects the register's size by June 30, 2027, when the Commission is due to report on MiCA's implementation.