MiCA Tracker

An authorised crypto-asset service provider (CASP) complies with Title V of MiCA and its technical standards: authorisation, governance, conflicts of interest, complaints handling, continuity of service, record-keeping and prevention of market abuse. Several other regimes apply on top. The travel rule under Regulation (EU) 2023/1113, applicable since 30 December 2024, requires information on the originator and the beneficiary to accompany each transfer. Anti-money laundering and countering the financing of terrorism (AML/CFT) rules currently derive from the French Monetary and Financial Code (CMF) and, from 10 July 2027, from Regulation (EU) 2024/1624 (AMLR). Regulation (EU) 2022/2554 on digital operational resilience (DORA) has applied since 17 January 2025. Directive (EU) 2023/2226 (DAC8) has required providers to collect information on their users and their transactions since 1 January 2026, with a first report to the French tax authorities due by 15 June 2027. French law applies as well: Ordinances No 2024-936 and No 2024-937 of 15 October 2024, their implementing decrees, and the AMF General Regulation and guidance. We help you obtain CASP authorisation and advise on MiCA compliance for authorised CASPs, AML/CFT for CASPs and DORA compliance; our tax practice group handles DAC8 obligations.

A person who offers to the public crypto-assets other than ARTs and EMTs, or seeks their admission to trading, falls under Title II of MiCA. That person draws up a crypto-asset white paper in line with Annex I and notifies it to the competent authority (Article 8), in the machine-readable format set by Implementing Regulation (EU) 2024/2984 and with the sustainability indicators of Delegated Regulation (EU) 2025/422. The rules on marketing communications (Article 7), the general obligations of Article 14 and the disclosure of inside information (Article 88 and Implementing Regulation (EU) 2024/2861) also apply. Upstream, the classification of the token determines everything else: ESMA’s guidelines on the qualification of crypto-assets as financial instruments (Article 2(5)) and the joint guidelines of the European supervisory authorities on the classification test (Article 97) set out the method. See our pages on classifying a token under MiCA, MiCA white paper and token launch and tokenising real-world assets.

Only a credit institution or an electronic money institution may offer an e-money token (EMT) to the public or seek its admission to trading (Article 48). The issuer notifies its white paper to the competent authority, the ACPR in France, and complies with Title IV: issuance and redemption at par value, redemption at any time, no interest granted to holders, and investment of the funds received. When the EMT becomes significant under Delegated Regulation (EU) 2024/1506, the stricter requirements of Articles 56 to 58 apply, and the EBA takes part in supervision. A payment institution cannot issue EMTs, but it often works alongside CASPs: it may hold their clients’ funds (Q&A ESMA_QA_2949) and provide payment services involving EMTs (EBA opinion on the interplay between PSD2 and MiCA). The tracker also follows the texts specific to issuers of asset-referenced tokens (ARTs). See our pages on issuing a stablecoin under MiCA, payment and electronic money institutions and CASP and payment institution dual licensing.

A credit institution, central securities depository, investment firm, electronic money institution, UCITS management company or alternative investment fund manager may provide crypto-asset services without CASP authorisation, by notifying its competent authority at least 40 working days before it starts (Article 60). The services open to it depend on its status. These entities remain subject to most of the rules that apply to CASPs, including the travel rule, AML/CFT and DORA. The “Financial entities (Art. 60)” filter isolates the texts specific to them, in particular the technical standards on notification (Regulations (EU) 2025/303 and 2025/304) and ESMA’s Q&As on credit institutions and alternative investment fund managers.