European Union
MiCA is now fully operational across the EU-27. Passportable CASP authorisation, ART/EMT issuer rules, and the new AMLA supervisor make the EU the reference point for globally-scaled crypto regulation. Grandfathering windows are closing through 2026 — the enforcement phase is beginning.
Comprehensive
ESMA · EBA · National Competent Authorities (BaFin, AMF, CONSOB, CNMV, CSSF, MFSA)
MiCA (Regulation 2023/1114) — harmonised CASP authorisation, ART and EMT issuer regimes; passportable across 27 Member States.
AMLD5/6, Transfer of Funds Regulation (TFR) — Travel Rule since 30 Dec 2024, €1 tx threshold; AMLA supervisor operational.
Implemented — TFR removes de minimis threshold; self-hosted wallet transfers >€1,000 require additional verification.
Harmonised only for DAC8 reporting; income and capital treatment remains national.
MiCA white paper, marketing communications rules, and complaint-handling requirements; ART/EMT redemption rights.
First fully harmonised crypto asset regime; ART/EMT rules live June 2024, CASP rules Dec 2024.
Travel Rule with zero de minimis; extends to self-hosted wallets.
Crypto-asset reporting to tax authorities from 2026.
Direct supervision of high-risk cross-border CASPs begins Q3 2026.
First public denials — governance and reserve deficiencies cited.