Banking Access for Licensed CASPs: What Works in the EU in 2026

Why banking is the friction point post-authorisation

A MiCA authorisation answers the supervisory question: is this firm fit and proper, properly capitalised, and properly governed to provide crypto-asset services? It does not answer the operational question: which bank will hold the firm’s operating funds, settle client fiat in and out, and accept the AML risk of the firm’s customer base?

The two questions overlap heavily but are not the same. Several authorised CASPs in 2025-2026 found themselves in the gap — licensed by the supervisor, unbanked by every EEA institution they approached, unable to onboard customer fiat flow for an extended period.

The friction is structural. EEA banks do not have a generic appetite for crypto-asset business. Their internal risk frameworks were built around traditional financial-services counterparts; CASPs sit outside those frameworks even when fully licensed. The adjustment is happening — slowly, jurisdiction by jurisdiction, bank by bank. The 2026 reality is that the CASP without a banking strategy is the CASP that operates after the lawyers stop billing and the operational team starts asking where to settle.

What MiCA actually requires on the banking side

Two specific MiCA articles drive the banking workstream:

The client-asset safeguarding rule — Safeguarding of clients’ funds. Where a CASP holds clients’ funds (typically fiat received pending a crypto-asset purchase, or fiat held pending a withdrawal), those funds must be:

• Deposited at an EEA-authorised credit institution or central bank
• Segregated from the CASP’s own assets
• Identified separately in accounting from other client funds and CASP funds
• Not used by the CASP for its own account

This is the core safeguarding rule. It does not prescribe which credit institution — only that the chain ends at one. A CASP can hold the operating account at an EMI, provided the EMI itself safeguards the funds at a credit institution or central bank.

The custody-service rulebook — Operational requirements for trading platforms. Class 3 firms operating a trading platform have additional operational rules including settlement-related expectations that influence banking choice.

Beyond MiCA itself, the EBA Opinion on the interplay between PSD2 and MiCA, published in June 2025, clarifies how PSD2 payment-services rules apply to hybrid CASP arrangements. Several CASP business models include a payment-services component — fiat on/off ramps, customer top-up flows, withdrawal routing — that sits at the PSD2-MiCA boundary. The EBA opinion sets out the supervisory expectation for these arrangements.

What banking patterns actually work in 2026?

The CASPs we observe operating successfully in 2026 use one or more of these patterns:

1. Direct EEA bank relationship (the cleanest pattern, hardest to obtain). A direct operating account at an EEA-authorised credit institution that knows and accepts the CASP’s risk profile. Typically a smaller specialist or challenger bank rather than a domestic universal bank. Limited inventory in the market — material lead time for onboarding (months, not weeks).

2. EMI partnership. Many CASPs use an EMI (electronic money institution) for the fiat-rail layer. The EMI holds the CASP’s operating funds, processes customer fiat in/out, and itself safeguards funds at a credit institution. This pattern is operationally common for retail-facing CASPs — the EMI brings the fiat-rail integration; the CASP brings the crypto-asset service layer. The EBA Opinion clarifies the supervisory expectation for these arrangements.

3. Banking-as-a-service partner. A specialist BaaS provider acts as the banking layer for the CASP, providing operating accounts, payment rails, and (in some cases) safeguarding-grade client-money infrastructure as a service. The provider itself holds the regulated banking authorisation; the CASP integrates via API.

4. Multi-bank redundancy. Mature CASPs hold at least two operating banking relationships, typically spread across jurisdictions, so that loss of one does not stop the firm. Particular in the wake of de-banking events that have hit several authorised CASPs in 2025-2026, redundancy is a planning default rather than an exception.

The right pattern depends on the CASP’s business model, expected fiat-flow volume, and risk tolerance. For most retail-facing Class 2 firms, Pattern 2 (EMI partnership) is the practical default. For Class 3 trading platforms with institutional flow, Pattern 4 (multi-bank redundancy) typically becomes a planning requirement.

Stablecoin issuers: separate banking workstream

CASPs that also issue ARTs (Title III) or EMTs (Title IV) operate a second banking workstream entirely separate from the operational and client-funds workflows:

EMT issuers (the EMT reserve rule): Reserve assets must be held in deposits at credit institutions, in central bank reserves, or invested in secure low-risk assets. The composition, custody, segregation, and reporting rules are spelled out in Title IV. The reserve-banking arrangement is materially heavier than operational banking and typically requires direct relationships with multiple credit institutions for prudential reasons.

ART issuers (the ART reserve rule): Reserve assets backing the ART must be invested in highly liquid financial instruments, and the reserve arrangement is subject to specific composition, custody, and segregation rules. The supervisor reviews the reserve-banking arrangement as part of the ART issuer authorisation.

A CASP that also issues a stablecoin runs three parallel banking workstreams: operational, client-funds safeguarding (the client-asset safeguarding rule), and reserve-asset (the ART reserve rule or 54). Founders considering a hybrid model should plan all three from the start.

How does banking choice affect supervisory acceptance?

National supervisors take an interest in the CASP’s banking arrangement during authorisation review. The arrangement is not the supervisor’s primary subject of scrutiny, but it is a credibility signal:

• A documented operating-banking relationship at filing demonstrates seriousness
• A documented the client-asset safeguarding rule client-funds safeguarding arrangement is non-optional for filings where the CASP holds client funds
• A documented contingency plan for loss of the primary banking relationship demonstrates operational maturity

Filing without addressing banking is a substantive deficiency in supervisory practice. Files that delay banking arrangement to post-authorisation typically receive an information request seeking the operational plan, which extends the supervisory timeline.

Working with counsel and banking partners on the file

The diagnostic for counsel and banking partners on a CASP file is whether they can describe — concretely — how the firm’s specific business model maps to the four patterns above and what timeline each pattern requires. Counsel that gives generic answers about “banking for crypto firms” has not surfaced the business-specific decision points.

The firms in our index with relevant CASP-banking expertise are listed below.