Centralized exchange in European Union

Under MiCA the EBA supervises issuers of significant asset-referenced tokens and significant e-money tokens (Art 117, Regulation (EU) 2023/1114), decides on significance under its 22 October 2024 procedure, and drafts the ART/EMT technical standards and guidelines.

ESMA keeps the MiCA registers of CASPs, white papers and non-compliant entities (Arts 109–110, Regulation (EU) 2023/1114), drafts CASP technical standards and issues guidelines; day-to-day CASP authorisation and supervision sits with national competent authorities (Arts 62–63, 93).

CASP authorisation under MiCA is granted by the national competent authority of the home Member State (Arts 62–63, Regulation (EU) 2023/1114), for example BaFin, the AMF, the CNMV and the Central Bank of Ireland, which appear as authorising NCAs in the ESMA register.

MiCA, Regulation (EU) 2023/1114 of 31 May 2023 (OJ L 150, 9.6.2023, p. 40), governs CASP authorisation, crypto-asset white papers and ART/EMT issuance; Titles III and IV (ARTs and EMTs) apply from 30 June 2024 and the rest, including CASP rules, from 30 December 2024 (Art 149).

The recast Transfer of Funds Regulation, Regulation (EU) 2023/1113, has applied since 30 December 2024 and requires originator and beneficiary information on every crypto-asset transfer regardless of amount; transfers exceeding EUR 1,000 to or from a self-hosted address also trigger a CASP check of ownership or control of that address.

AMLD6, Directive (EU) 2024/1640 of 31 May 2024, sets the national AML/CFT supervisory and FIU framework; Member States must transpose it by 10 July 2027, when it repeals Directive (EU) 2015/849, the AML directive that still applies to CASPs until then.

DAC8, Council Directive (EU) 2023/2226 of 17 October 2023, extends EU automatic exchange of tax information to crypto-assets; Member States had to transpose it by 31 December 2025 and apply it from 1 January 2026, with first reports covering calendar year 2026.

MiCA lists 10 crypto-asset services (Art 3(1)(16)) grouped in three minimum-capital classes (Annex IV): Class 1 EUR 50,000 (execution, placing, transfer, reception/transmission, advice, portfolio management); Class 2 EUR 125,000 (adds custody, exchange for funds, exchange crypto-for-crypto); Class 3 EUR 150,000 (trading platform); the requirement is the higher of that amount or one quarter of prior-year fixed overheads (Art 67(1)).

Under MiCA a CASP providing custody and administration of crypto-assets on behalf of clients is a Class 2 provider with minimum capital of EUR 125,000, or one quarter of prior-year fixed overheads if higher (Art 67(1), Annex IV), and must segregate client crypto-assets from its own holdings, including on the distributed ledger (Art 75(7)).

A CASP authorised for exchange of crypto-assets for funds or other crypto-assets is a Class 2 provider (EUR 125,000 minimum capital, MiCA Annex IV); to passport, it notifies its home NCA, which forwards the notice to host states within 10 working days, and services may start on receipt or at the latest on the 15th calendar day (Art 65). France kept the full 18-month transition; Germany chose 12 months.

The EU travel rule for crypto-assets is Regulation (EU) 2023/1113, applicable since 30 December 2024 (Art. 40): originator and beneficiary information must accompany every crypto-asset transfer with no minimum amount, while a separate EUR 1,000 trigger requires the CASP to assess whether a self-hosted address is owned or controlled by its client (Arts 14(5), 16(2)).

Regulation (EU) 2023/1113, the recast Transfer of Funds Regulation, was adopted on 31 May 2023, published in OJ L 150 of 9 June 2023, entered into force on the twentieth day after publication and has applied since 30 December 2024 (Art. 40). The EBA travel-rule guidelines (EBA/GL/2024/11, 4 July 2024) also apply from 30 December 2024.

Regulation (EU) 2023/1113 sets no de minimis threshold for crypto-asset transfers: recital 30 states they are subject to the same requirements regardless of amount and whether domestic or cross-border. The only EUR 1,000 figure for crypto-assets is the self-hosted address ownership check in Arts 14(5) and 16(2).

Regulation (EU) 2023/1113 applies to crypto-asset service providers as defined in Article 3(1)(15) of MiCA (Regulation (EU) 2023/1114) and to intermediary CASPs, meaning CASPs that receive and transmit a crypto-asset transfer on behalf of the originator's or beneficiary's CASP; a transfer is in scope when at least one CASP carries it out.

Under Article 14 of Regulation (EU) 2023/1113 the originator's CASP must send the originator's name, distributed ledger address or account number, address or official document number or date and place of birth, and LEI where available, plus the beneficiary's name and address or account, in advance of or simultaneously with the transfer and securely. EBA Guidelines EBA/GL/2024/11 of 4 July 2024 on detecting and handling missing information apply from 30 December 2024 and repeal Guidelines JC/GL/2017/16.

Regulation (EU) 2023/1113 of 31 May 2023 (OJ L 150, 9.6.2023, p. 1) recast the EU Transfer of Funds Regulation to cover transfers of crypto-assets and repealed Regulation (EU) 2015/847 from its date of application, 30 December 2024 (Arts 39 and 40).

EBA Guidelines EBA/GL/2024/11 of 4 July 2024 on information requirements for transfers of funds and certain crypto-assets under Regulation (EU) 2023/1113 set how payment service providers and CASPs detect and handle missing or incomplete originator and beneficiary information; they apply from 30 December 2024.

In January 2026, the French Autorité des Marchés Financiers (AMF) became the first NCA to publicly announce a formal enforcement action under MiCA, issuing a cease-and-desist order against an unregistered non-EU CASP (CryptoFlow Ltd., registered in the Cayman Islands) for soliciting French residents without authorization; the AMF noted this action as a "test case" for MiCA enforcement coordination across NCAs AMF MiCA Enforcement Action January 2026

A March 2026 analysis by the European Systemic Risk Board (ESRB) identified that 8 of the 27 EU NCAs had not yet finalized their MiCA enforcement guidelines by Q1 2026, creating "supervisory fragmentation risks" for CASPs operating across multiple member states; the ESRB warned that this could lead to inconsistent application of authorization requirements and investor protections by the April 2026 enforcement date ESRB Analysis of MiCA Supervisory Fragmentation

The European Commission's March 2026 enforcement update confirmed that the Netherlands Authority for the Financial Markets (AFM) had issued formal warnings to 14 crypto-asset firms for failing to submit complete authorization applications by the February 28, 2026 deadline; the AFM warned that firms without approved authorization by April 1, 2026, would face immediate suspension orders European Commission MiCA Enforcement Update March 2026

Under MiCA (Regulation (EU) 2023/1114), the NCAs designated under Art 93 hold the supervisory and investigative powers in Art 94, including suspending a CASP's services for up to 30 consecutive working days, prohibiting crypto-asset services and publicly naming a CASP that fails its obligations; Art 111 requires administrative penalties and Art 114 requires penalty decisions to be published. Since the Art 143(3) transitional regime ended on 1 July 2026, no unauthorised CASP has grandfathering cover.

On 17 December 2024 ESMA published a Statement on MiCA transitional measures (ESMA75-453128700-1396) explaining that Member States chose different grandfathering periods under MiCA Art 143(3) and that a CASP serving clients in several Member States must comply with each state's law, so that a shorter national transitional period does not expire before it holds a MiCA authorisation.

Practical enforcement examples by April 2026 remain limited; however, in late 2025, the Dutch Authority for the Financial Markets (AFM) issued warnings against several unregistered crypto firms operating without transitional provisions AFM Crypto Warnings

MiCA Art 143(3), not Art 127, lets crypto-asset service providers that operated lawfully before 30 December 2024 continue until 1 July 2026 and lets each Member State shorten or disapply that period; per ESMA's list, Germany chose 12 months and France the full 18 months, while Latvia, Hungary, the Netherlands, Poland, Slovenia and Finland chose 6 months.

By April 2026, ESMA and NCAs will have conducted at least one round of thematic reviews and supervisory stress tests on authorized CASPs, focusing on governance, custody of client assets, and disclosure requirements, as part of ESMA's 2025-2026 Supervisory Convergence Work Programme ESMA Work Programme 2025