As the year 2025 begins, the cryptocurrency sector finds itself at a pivotal moment. The anticipated policy shift regarding cryptocurrencies in the United States, in the wake of the second Trump administration, coincides with the complete implementation of the European Regulation on Markets in Crypto Assets (MiCA). This legislation is arguably the most thorough effort to regulate digital currencies seen to date.
To summarize MiCA, the first phase of implementation for stablecoins—termed “Asset Reference Tokens” or “E-Money Tokens” within the legislative language—was initiated on June 30, 2024. The second phase, which took effect on December 30, 2024, expanded the regulations to include all other types of regulated tokens, coins, and crypto assets service providers (CASPs), which encompass exchanges, custodians, trading platforms, and various intermediaries servicing customers.
Much has been discussed regarding the requirements MiCA places on issuers of stablecoins, other cryptocurrencies, and significantly on those entities defined as CASPs. These entities are now recognized as entities subject to supervision. Observations and insights from industry participants indicate that many firms potentially qualifying as CASPs are aware of MiCA’s impact and thus have sought legal counsel or initiated processes for authorization in EU member states.
However, a significant aspect of MiCA’s influence remains underexplored: its ramifications for various non-regulated participants in the crypto ecosystem, including technical vendors, infrastructure developers, decentralized finance (DeFi) platforms, marketing professionals, investors, and day traders. While these entities do not directly fall under regulatory supervision, the new standards established by MiCA are expected to considerably affect their operations.
New regulations often carry a cascading effect within an industry. When statutory obligations are imposed on specific entities, they influence not only those directly regulated but also extend impact to any related parties or secondary entities. This diffusion means that obligations, including compliance processes, can extend to organizations that do business with, or engage with, regulated firms.
Significantly, some of MiCA’s provisions create an implicit mechanism where the responsibilities of regulated entities, like CASPs and token issuers, could ‘pass on’ to non-regulated players. CASPs and token issuers must manage their relationships carefully with third-party suppliers to ensure compliance, which in turn places obligations on vendors and partners as well.
For instance, software vendors building services for blockchain and digital assets must be aware of MiCA’s requirements as it directly affects their clientele’s compliance landscape. Failure to meet these needs may result in regulated clients opting for alternative suppliers, threatening the vendor’s role in the market.
Furthermore, an infrastructure platform that assists exchanges and custodians with client funds, despite not qualifying as a CASP itself, would still find itself subject to the MiCA framework if its services are directed toward regulated entities. Therefore, service providers need to align their technological offerings to support their clients in complying with MiCA’s comprehensive regulations, which include operational resilience, cybersecurity, anti-money laundering, and ongoing cooperation with authorities.
Some vendors may have even revisited the design of their services to ensure they meet new compliance standards demanded by MiCA and its associated regulations like the Digital Operational Resilience Act (DORA), which may impose further obligations on firms deemed critical.
Additionally, MiCA introduces overarching rules applicable to all market participants, addressing issues like market manipulation and insider trading. These provisions can have significant implications for various players, from DeFi traders to institutional investors, as they are expected to adhere to the same anti-abuse standards. Those privy to sensitive information must evaluate their operations to prevent any potential regulatory breaches.
While MiCA does not equate non-regulated firms with those under direct supervision, it still imposes indirect compliance burdens across the broader crypto ecosystem. The principal regulatory demands focus on firms interacting directly with consumers, namely token issuers and CASPs. However, this comprehensive regulation sets off a chain reaction influencing varied industry players, leading to a necessary evolution in how technological solutions and business practices are developed to ensure alignment with future regulatory standards.
As 2025 unfolds, the crypto landscape’s adaptability will be tested, especially as expectations rise for compliance amid increasing regulatory scrutiny on a global scale. Those invested in technological innovations must prioritize building solutions that adequately support regulatory frameworks to remain competitive in this shifting environment.