Markets in Crypto-Assets (MiCA) finally flipped from rulebook-in-waiting to hard law this year. With the stablecoin provisions live since 30 June 2024 and the full Crypto-Asset Service Provider (CASP) regime in force from 30 December 2024, Europe’s crypto sector has just experienced its first full calendar month under the entire framework.
1 | Why MiCA matters—timeline at a glance
- 29 June 2023: Regulation entered the EU’s Official Journal; countdown began.
- 30 June 2024: Title III & IV activated—asset-referenced tokens (ARTs) and e-money tokens (EMTs, i.e. most “stablecoins”) now need authorisation and must respect hard caps. (chainalysis.com)
- 30 December 2024: Title V switched on—any exchange, broker, custodian or DeFi front-end that qualifies as a CASP must hold an EU-wide licence. (legarithm.io)
MiCA’s phased roll-out was meant to give issuers and platforms breathing room, yet the past four weeks show many are still scrambling to close compliance gaps.
2 | The cap heard round the market
The headline constraint is “1 million transactions or €200 million in daily value”—cross either threshold and regulators may order a suspension until systemic-risk reviews conclude. (shiftmarkets.com, fireblocks.com)
Winners and losers so far
| Token | Month-one EU share* | Status | Comment |
|---|---|---|---|
| USDT | ▼ to 61 % | At risk | Multiple exchanges announced delistings or transfer limits. (en.cryptonomist.ch) |
| USDC | ▲ to 24 % | Compliant | Now minted by Circle France under an EMI licence. (circle.com) |
| EURC / EURCV / EURI / EURe / EURS | ▲ to 9 % combined | Compliant | Euro wave accelerated by cap pressure on USD tokens. (innreg.com) |
*Share of stablecoin volume on EU-registered exchanges, 1 – 30 June 2025, Kaiko data.
Notably, ESMA clarified that custody and transfers of non-compliant tokens are “not explicitly prohibited,” yet it “encourages” withdrawals to cease after supervisory cut-offs—guidance that pushed several brokers to pre-emptively restrict USDT. (cointelegraph.com)
3 | Licence land-grab—first wave statistics
Skadden’s six-month retrospective counts 42 CASP licences issued across 17 member states, led by Germany (11) and the Netherlands (8). (skadden.com)
Why the rush?
- Passporting gold-rush: one licence opens 30 EEA markets.
- Capital rules: €125k – €150k initial capital is far lower than full banking tiers. (maxcorp.eu)
- Marketing edge: exchanges flaunt MiCA approval in banner ads to reassure retail investors scarred by FTX.
The public ESMA interim register now lists all authorised CASPs and white-paper IDs, creating de facto “green lists” that wallets and OTC desks can auto-screen. (esma.europa.eu)
Yet implementation is uneven: Portugal’s delayed transposition left local applicants in limbo and forced them to file in neighbouring Spain to keep pan-EU ambitions alive. (wyden.io)
4 | Issuer playbook—work-arounds & new strategies
Offshore mint, on-chain wrapper. Several USD-backed issuers now structure a Cayman SPV to mint tokens, then allow EU traders to swap into wrapped versions on permission-less bridges. Lawyers argue these wrappers are “other tokens” outside Titles III–IV. Expect NCAs to challenge that view.
Algorithmic re-brands. Projects formerly touting “algorithmic stablecoin” status now pivot to “synthetic commodity” labels, claiming they track CPI baskets, not fiat—an attempt to dodge the EMT/ART definition.
Delist-to-persist. Tether halted new EURT issuance last winter and signalled a MiCA-compliant alternative “by November 2025,” but pulled USDT marketing from EU websites to avoid the “offer to the public” trigger. (vixio.com)
Licence-by-acquisition. Two major Asia-based brokers quietly bought MiCA-approved Lithuanian entities to inherit authorisations, mirroring the e-money M&A playbook of the 2010s.
5 | The euro stablecoin renaissance
Policy-makers hoped caps would nudge the market toward euro liquidity, and early data suggest it’s working: euro-denominated coins broke the 10 % market-share line for the first time in late June.
MiCA-ready euro tokens in circulation (July 2025)
- EURC (Circle): Fully backed cash & T-bills, daily attestation. (circle.com)
- EURCV (Société Générale): Bank-issued, listed on Bitstamp. (innreg.com)
- EURI (Banking Circle): Cross-border B2B payments focus. (innreg.com)
- EURe (Monerium): On-chain SEPA settlement rails. (innreg.com)
- EURS (Stasis): MiFID custody with ClearBank. (innreg.com)
Expect the ECB to monitor euro-stable volumes closely as it prototypes the digital euro; MiCA grants it veto power if private supply threatens monetary policy.
6 | MiCA compliance checklist for exchanges (CASPs)
Use this nine-point list to survive the next supervisory audit.
- Secure a CASP licence with your National Competent Authority; file articles, governance chart and five-year forecast under Art. 63. (manimama.eu)
- Maintain €125k+ capital (spot venue); €150k+ if also offering custody. (maxcorp.eu)
- Publish a MiCA-format white-paper for every token you list—yes, even wrapped assets.
- Daily stablecoin-cap monitor: integrate on-chain analytics to auto-halt deposits once they near the 1 M / €200 M limits.
- Travel-Rule integration: collect sender/receiver data on transfers > €1,000 and share via FATF-compliant API. (orcabay.io)
- Segregate client funds in an EU credit institution; no rehypothecation unless expressly authorised.
- Quarterly cyber-audit & vulnerability scan filed with ESMA and NCA. (chainup.com)
- Real-time market-abuse surveillance aligned to ESMA’s April 2025 guidelines (wash-trade, pump detection). (esma.europa.eu)
- GDPR dovetail: cross-check every new KYC vendor for data-export restrictions.
7 | What’s next?
The technical standards pipeline is far from empty. ESMA must finalise order-book transparency RTS by 30 December 2025, while the EBA will pilot a real-time stablecoin dashboard to flag cap breaches automatically. Expect national supervisors to harden enforcement once the transitional grace period ends on 30 June 2026.
For issuers and exchanges, the best defence is speed: front-load your licence, over-invest in cap monitoring, and embrace euro liquidity early. MiCA’s first month has shown that regulators are willing to nudge, cajole and—where needed—pull the plug. Those who adapt quickly may discover that compliance is not a cost centre but a competitive moat.