MiCA Implementation: Operational State of Play, Q1 2026
Eighteen months after MiCA entered into force, the operational posture of CASPs, banks, and supervisors is materially different across member states. We map the gaps that matter for institutional digital-asset infrastructure.
MiCA — the EU Markets in Crypto-Assets regulation — is now eighteen months past initial entry into force. The original premise was elegant: a single regulatory framework spanning all twenty-seven member states, harmonising the obligations of crypto-asset service providers (CASPs) with the supervisory expectations of traditional finance.
Eighteen months in, the operational reality is more uneven than the regulation reads. Some national competent authorities have built dedicated digital-asset supervisory teams; others continue to delegate. Some have published clear timelines for the transitional regime; others have left it to interpretation. For institutional infrastructure operators, this divergence is the central planning constraint of 2026.
We map the gaps that matter — passporting friction, stablecoin perimeter ambiguities, custody-asset segregation rules, and the practical timelines under which a regulated infrastructure provider can operate cross-border in the EU without surprise.
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