The European Union's Markets in Crypto-Assets regulation, MiCA, took full effect on July 1, ending the transitional grandfathering window for crypto-asset service providers and forcing any unlicensed CASPs to cease European operations. With the framework now binding, the European Commission has opened a formal consultation, launched in May, to assess whether the rules drafted between 2020 and 2023 still fit a market reshaped by stablecoins and tokenization.
Stablecoins are the standout pressure point. Around 20 euro-denominated stablecoins have been authorized under MiCA, but the regime's reserve rules and minimum bank-deposit requirements are now being measured against the U.S. GENIUS Act and competing frameworks in Hong Kong. Patrick Hansen, Circle's director of EU strategy and policy, framed the consultation as a routine "version one" review rather than a sign MiCA fell short, telling CoinDesk it "makes sense to go back to the drawing board and adjust what's working potentially less well compared to other frameworks."
Why it matters
The Commission is weighing several structural changes, most notably a third-country equivalence regime that would let tokens regulated abroad circulate inside the EU through mutual recognition. Sebastian Barling, a financial regulation partner at Skadden, told CoinDesk the consultation is "clearly a serious review intended to make sure the European regime aligns internationally and remains competitive." His colleague Eva Legler counsel at Skadden added that CASPs dominated the original draft because stablecoins had not yet grown into the payments infrastructure they are today.
The Commission is also examining tighter redemption safeguards for multi-issuance arrangements, where the same issuer runs pools across jurisdictions. Requiring separate issuance and liquidity pools, Barling warned, risks "undermining the efficiency that makes stablecoins valuable in the first place."
Market impact
The next phase of policymaking could extend beyond stablecoins into tokenized real-world assets, a category Barling said has dominated his 2026 client work.
Frequently asked questions
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What is MiCA and when did it take full effect?
MiCA, the EU's Markets in Crypto-Assets regulation, took full effect on July 1, ending the transitional grandfathering period that let crypto-asset service providers operate without full licensing. Unlicensed CASPs must now cease European operations.
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Why is the European Commission reviewing MiCA so soon after launch?
The Commission opened a consultation in May because MiCA was drafted between 2020 and 2023, when exchanges were the primary focus. Stablecoins and tokenized assets have since moved to the center of the market, and the EU wants its rules benchmarked against the U.S. GENIUS Act and Hong Kong's framework.
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How does MiCA treat stablecoins differently from the U.S. GENIUS Act?
MiCA requires stablecoin issuers to hold minimum bank deposits and meet reserve-composition rules, which critics say are stricter than the U.S. approach. Around 20 euro-denominated stablecoins have been authorized, but the reserve requirements are now a central focus of the Commission's review.
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What is a third-country equivalence regime and why does it matter?
An equivalence regime would let crypto tokens regulated in another jurisdiction circulate inside the EU through mutual recognition. Skadden partner Sebastian Barling told CoinDesk such a regime could transform the market by letting globally issued stablecoins list on EU exchanges without separate EU licensing.
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Could MiCA amendments affect tokenized real-world assets?
Yes. Skadden partner Sebastian Barling said tokenized real-world assets now dominate his regulatory work in 2026 and that the next phase of MiCA will extend well beyond the original CASP focus to cover tokenization and cross-border issuance.
CoinDesk