"One Year of MiCA: The Market in Figures and the Challenges Ahead"

MiCA has brought significant standardization to the market. According to the latest European Securities and Markets Authority (ESMA) register as of December 2025, the sector now has 102 crypto-asset service providers (CASPs) operating in the EU. Banks are also actively involved—12 of the registered CASPs are credit institutions—helping to expand the range of secure services available. In contrast, the stablecoin issuer market is still less developed, with just 30 active issuers.

The ESMA CASP register only includes entities with full MiCA authorization, excluding those operating temporarily under the transitional regime. As a result, the current figures do not account for all pre-existing operators, who have until July 1, 2026 to obtain their license—the deadline for the transition period. In a recent development, the European Commission has proposed centralizing supervision of CASPs within ESMA, moving it away from national authorities.

MiCA has brought significant standardization to the market.

At the international level, both the US and the UK have followed the EU's regulatory lead by introducing their own regimes. In the United States, this has taken the form of the Genius Act on stablecoins. In the United Kingdom, the FCA has launched a consultation on applying its regulatory framework to crypto-asset activities, while the Bank of England has opened a consultation on a regime for systemic stablecoins denominated in pounds.

While MiCA's main motivation was to address the risks stablecoins pose to consumers, financial stability, and monetary sovereignty—with a particular focus on stablecoins pegged to other currencies—the US has an explicit policy goal of promoting dollar-pegged stablecoins as a way to strengthen the dollar's international role. Although their policy objectives differ, there are important similarities when it comes to stablecoin regulation

On the regulatory front, the challenge now is ensuring interoperability between regimes in different jurisdictions, to avoid fragmenting a market that is global by nature.

Two of the most controversial points in these regulations concern the payment of interest to stablecoin holders and multi-issuance across jurisdictions. In the US, banks have criticized the legislation for not extending the prohibition on interest payments to distribution intermediaries (exchange platforms or custodians)—a “loophole” that could increase the risk of bank deposits being replaced by stablecoins. In contrast, MiCA's prohibition is clearer.

In the US, banks have criticized the legislation for not extending the prohibition on interest payments to distribution intermediaries

Multi-issuance is a mechanism whereby entities in different jurisdictions can issue identical, fungible stablecoins, but under different regulatory regimes and backed by separate asset reserves. MiCA does not expressly regulate this practice, but its use in the market has sparked intense debate among European institutions about the risks it may pose to European consumers—specifically, whether reserves might be insufficient to cover stablecoin circulation, and whether MiCA's current framework offers the necessary safeguards. This debate underscores the importance of interoperability between different regulatory frameworks and the need for international convergence. While the Genius Act envisages reciprocal agreements for foreign issuers subject to comparable supervision, MiCA does not include such provisions—meaning multi-issuance would be the only possible route to interoperability.

To address this debate, the European Commission is expected to issue guidance clarifying the treatment of multi-issuance schemes under MiCA, to assist authorities in their supervision. Looking ahead, the regulation already acknowledged its own limits and includes a mandate for the European Commission to report on matters outside MiCA's scope: Decentralized Finance (DeFi), lending, and NFTs not currently covered.

The European Commission is expected to issue guidance clarifying the treatment of multi-issuance schemes under MiCA, to assist authorities in their supervision.

While clarity on these outstanding issues is still awaited, the priority for jurisdictions must be to pursue interoperability between their frameworks. Only by doing so can they mitigate fragmentation and ensure that legislation keeps pace with evolving markets and their global scale.