In conversation with... Erik Becker, Product Director at Regnology

What types of firms does MiCAR apply to, and what do they need to do to comply?  

MiCAR imposes new obligations on both primary and secondary markets that address many aspects of crypto asset market structure, including investor protection, transparency, anti-money laundering measures and safeguards against market abuse.

In terms of who is affected, MiCAR applies to both individuals and larger entities. A number of firms will be designated as Crypto-Asset Service Providers (CASPs): issuers, traders, brokers, custodians and financial institutions offering services related to crypto-assets.

MiCAR effectively introduces a “passporting” system through which CASPs and Crypto-Asset Issuers (CAIs) will operate across the entire EU with one license. CASPs are required to obtain EU-wide authorization, meet rigorous operational standards and comply with capital, risk management and consumer protection requirements. CAIs must provide detailed whitepapers and adhere to strict transparency and investor protection standards.

What are the challenges these firms are likely to face in achieving MiCAR compliance? 

To navigate the evolving regulatory landscape and maintain their competitive edge, CASPs and CAIs need to stay nimble and be ready to adapt to avoid MiCAR-related penalties. Operational adjustments and regulatory engagement are essential.

Responsibilities under MiCAR are divided into three main categories: whitepaper requirements, organizational requirements and conduct requirements.  The challenge we foresee for CASPs and CAIs is in determining what rules need to be applied – not only understanding the complexity of the requirements, but also knowing what boxes to check from a technical and operational perspective.

Also, the impact of MiCAR will go beyond just the EU; as crypto asset adoption increases globally, firms must act prudently and understand their obligations based on their role in the larger ecosystem. Time is of the essence.

What roles do ESMA and the EBA play in implementing and enforcing MiCAR? 

ESMA is responsible for developing Regulatory Technical Standards (RTS) and Implementing Technical Standards (ITS) to ensure consistent application of MiCAR across the EU. These standards cover application procedures, complaint handling, conflict of interest management, market transparency and beyond.

The EBA is responsible for developing among other RTS and ITS focused on ARTs and EMTs specifically, so that these vehicles meet the necessary capital and liquidity requirements for financial stability.

MiCAR reflects some of the broader industry trends we’re observing around data granularity.

By increasing requirements for crypto asset market participants, the regulation indicates familiar momentum toward more structured and data-driven reporting with a specific focus on this rapidly emerging asset class.

Erik Becker Product Director
Regnology

How does MiCAR dovetail with other EU regulatory requirements in the spotlight right now?   

MiCAR reflects some of the broader industry trends we’re observing around data granularity. By increasing requirements for crypto asset market participants, the regulation indicates familiar momentum toward more structured and data-driven reporting with a specific focus on this rapidly emerging asset class.

For example, the Basel Committee on Banking Supervision (BCBS) recently updated its global standards for bank exposures to crypto assets, mitigating systemic risks by requiring additional capital for higher-risk exposures. These updated standards will come into effect on January 1, 2026. In the Capital Requirements Regulation III (CRR III), transitional provisions for crypto-assets have already been adopted into the EU framework, but they still need to be adjusted in accordance with the BCBS update.

Increased compliance mandates for crypto market participants mean these firms must take a holistic approach to updating risk management frameworks, capital planning and data reporting processes to keep up with the evolving reporting standards.

Looking ahead, how is the regulatory landscape for crypto assets and related financial activities likely to evolve?

We predict that the regulatory landscape for crypto assets will tighten further as regulators seek to foster a unified, secure and transparent market. MiCAR represents a wider shift toward data-driven regulatory strategies. The update to the Macroeconomic Statistics Reporting (MESREP) framework in the Netherlands, with the first reporting date from March 2025 using DPM 3.0, is another notable example that shows where we could be heading.

Real-time, highly detailed reporting will become central to future regulatory efforts, promoting more comprehensive compliance with EU standards on best execution, conflict of interest, client asset management and beyond. MiCAR’s goals of consumer protection and market fairness may well set a global precedent, encouraging other jurisdictions to adopt similar frameworks.