MiCA in year two: what changed for issuers

The EU's Markets in Crypto-Assets regulation entered full application in mid-2024 for stablecoins and end-2024 for CASPs (crypto-asset service providers). Two years in, the operational picture is clearer than the launch predictions suggested.

Written August 2026 from a survey of MiCA-compliant issuers and CASPs.

What actually changed

• E-money token issuers face bank-like requirements. Reserve backing 1:1, custody of reserves at credit institutions, regular attestation. Some issuers exited the EU market rather than comply.
• Asset-referenced token issuers face additional stress tests. Reserve composition constraints, redemption rights, governance requirements. The compliance cost is real.
• CASPs need authorisation and passporting. The single-authorisation model means an authorised CASP can operate across the EU. In practice, the authorisation process has taken longer than issuers expected.
• Custody obligations are strict. Segregation of client assets, custody at authorised institutions, resolution planning. This is where several smaller players struggled.

What went smoother than expected

• Consumer disclosure requirements produced a cleaner comparison surface between issuers.
• Reserve attestations increased trust in the largest stablecoins.
• Passporting has worked reasonably well for established CASPs.

What's still contested

• Non-EU issuers offering services to EU customers. The line between "reverse solicitation" and "targeted marketing" is being contested case by case.
• DeFi's status under MiCA remains ambiguous; the exemption for genuinely decentralised protocols is narrow.
• The AMLR (Anti-Money Laundering Regulation) rollout affects CASPs on a different timeline; sequencing is a live issue.

MiCA is doing what regulation is supposed to do: raising the operational floor. The trade-off is real — some issuers left — but the market that remains is more institutional.