Overview
- MiCA enters its enforcement window through July 2026, requiring exchanges, custodians, stablecoin issuers and portfolio managers to secure EU authorization and ending third‑country equivalence.
- CASPs face banking‑style reporting, fees and capital reserve requirements that raise compliance costs and tend to benefit larger, well‑funded firms.
- ESMA’s “spectrum of decentralization” guides oversight of front‑ends and infrastructure providers, echoing the Tornado Cash precedent that targeted intermediaries rather than immutable code.
- Self‑custody wallets fall outside CASP scope, yet the Transfer of Funds Regulation compels CASPs to log transfers from private wallets above roughly €1,000 for AML and tax purposes.
- Poland remains the lone holdout after President Karol Nawrocki’s veto, with lawmakers needing a three‑fifths majority to overturn it, as the Commission proposes stronger ESMA powers to curb uneven implementation.