By the end of December 2025, the EU's regulatory framework for crypto assets, MiCA (Markets in Crypto-Assets), will celebrate its first anniversary of full implementation. This year marks not only the realization of regulation but also the inaugural year of formal competition between crypto-native institutions and traditional financial institutions at the same table.

Timeline

The implementation of MiCA has not been a sudden event but rather a meticulously planned process spanning several years. Over the past year, we have witnessed the entire journey of CASPs (Crypto Asset Service Providers) transitioning from "watching" to "rushing ahead."

Regulatory Focus

The regulatory focus of MiCA is no longer on abstract principles but rather on setting quantifiable and testable hard thresholds for the actual operations, asset protection, and market transparency of CASPs.

Here are the five core focuses of the MiCA regulatory framework:

Licensing and "Passporting" Mechanism

• Core: Replace fragmented national registrations with a single authorization. Once a CASP obtains authorization from its national NCA (National Competent Authority), it can "passport" its services to all 27 EU countries.

• Utility: Authorizations and passport notifications will be publicly listed in ESMA's (European Securities and Markets Authority) public register, facilitating verification by banks and partners.

Institutional "Substance" and Governance Requirements

• Core: Regulators require CASPs to have a genuine decision-making body within the EU, with at least one director residing in the EU—eliminating "mailbox company" setups.

• Requirements: ESMA/EBA (European Securities and Markets Authority/European Banking Authority) guidelines emphasize that management bodies and qualified shareholders must have clearly defined roles, time commitments, and capabilities.

Customer Funds and Asset Protection

• Core: Hard, testable controls. If a CASP receives customer fiat, it must deposit it in an EU credit institution or central bank by the end of the next business day and must never use customer assets for its own accounts.

• Liability: Requires segregation, daily reconciliation, clear custody contracts, and assumes liability for losses caused by its own negligence.

Trading Platforms and Brokers: Monitoring, Transparency, Records

• Core: Strengthen market monitoring and information disclosure. Trading platforms must monitor for market abuse and maintain complete order/traceable records.

• Data Requirements: Must disclose pre-trade and post-trade data (almost in real-time; free after a 15-minute delay) and keep it available for two years. Must retain multi-year order book data for regulators and standardize best execution principles.

Token Issuance: White Papers and Retail Protection

• Core: For tokens other than ARTs/EMTs, the issuer must be a legal entity and must draft, notify, and publish a crypto asset white paper before public issuance or access.

• Investor Protection: Retail buyers who purchase tokens before starting trading have a 14-day right of withdrawal. For tokens without a clear issuer (like BTC), platforms seeking access must assume disclosure and warning responsibilities.

Licensing Overview

The biggest benefit of MiCA lies in the "passporting mechanism." In the past, exchanges wanting to do business in Europe might have needed to apply for licenses in multiple countries such as Germany, France, and Italy. Now, obtaining a CASP license in one EU member state allows compliance to operate in all 27 member states.

This has led to a competitive "license battleground" over the past year. As of now, the licensing landscape is as follows:

Total licenses issued: 57

Popular registration locations:

• Germany: A "compliance fortress" for banks and custodians

• The country with the most licenses and the highest value, serving as the center for the integration of traditional finance and crypto.

• If institutions seek a "bank-grade compliance image" and wish to connect with deep capital markets, Germany is the preferred location for such "regular troops."

• Netherlands: The "artery" for payments and fiat channels

• The second-largest battleground after Germany, showcasing strong attributes of crypto-native and payment integration.

• The regulatory environment here is highly compatible with the broker model.

*The above image and content are sourced from AdamSmith.

Previously, fragmented regulations forced companies to scramble across countries, making compliance costs exorbitant. Now, the "passporting rights" granted by MiCA are no longer exclusive privileges for giants but the foundation for every licensed institution. Whether it is a top centralized exchange or an innovative startup focused on niche markets, obtaining a CASP license means opening a compliant highway to all 27 EU member states, covering a population of 450 million. This is the most profound transformation MiCA brings to the industry—it completely ends geographical arbitrage, making "compliance" the only passport for scaled expansion.

After Restructuring

Looking back at the year since MiCA's full implementation, the EU has ended the "Wild West" era of the crypto market with "one set of rules."

For practitioners, the "arbitrage era" is dead, and the "business development era" has arrived. Future competition will no longer be about who runs faster or who is bolder, but rather about who has lower compliance costs and who can more smoothly integrate into the deep waters of traditional finance.

MiCA is just the beginning. With regulatory frameworks in places like the UK and Singapore following suit, a global crypto compliance network has essentially taken shape. For crypto, this may no longer be the wild world filled with rugged heroes, but rather a new continent poised to carry trillions in funds due to the establishment of rules.

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