For CASPs, exchanges, custodians, and compliance teams operating or seeking authorisation in the EU. Six questions mapped to selected MiCA operational control expectations. Most platforms lack the real-time enforcement controls now expected under MiCA — find out where yours may be exposed. Indicative only, not legal advice.
Note: This assessment is indicative and does not constitute legal or regulatory advice. It covers selected operational controls only and does not address the full scope of MiCA requirements including licensing, capital, or governance obligations. Consult qualified legal and compliance counsel for a complete regulatory position.
The MiCA deadline of 1 July 2026 is the final cutoff for national transitional periods under MiCA Article 143. Grandfathered firms in France, Germany, and other member states must complete CASP registration with their National Competent Authority before this date. After 1 July 2026, operating without a CASP licence in the EU is unlawful. Authorisation processes typically take 6–18 months — firms that have not started are already behind.
Only asset-referenced tokens (ARTs) and e-money tokens (EMTs) authorised by an EU NCA with 1:1 reserve backing and a MiCA-approved white paper qualify as MiCA compliant stablecoins. CASPs may only list or custody MiCA-authorised tokens — continuous monitoring of issuer status is required, not a one-time check at listing.
ESMA guidance references automated surveillance tools as an expected component of a compliant MiCA monitoring programme. AI-driven pre-execution transaction simulation — applying risk verdicts before a transaction is signed — directly addresses MiCA’s prevention obligations under Art. 92 and the Travel Rule’s pre-execution requirements.
