MiCA's July 1 Deadline Is 103 Days Away. Most Crypto Brokers Are Not Ready.

Article 78 of MiCA introduces a binding best execution obligation for all crypto-asset service providers executing orders on behalf of clients.

This is not a principle. It is an enforceable standard — modelled directly on MiFID II — with penalties of up to **€5,000,000 or 3% of total annual turnover**, whichever is higher.

What best execution under MiCA actually requires:

- Continuous monitoring of price, cost, speed, and settlement conditions across all relevant venues
- Post-trade analytics demonstrating that outcomes were optimal at the time of execution
- Records retained for a minimum of **5 years** (Article 76)
- An auditable, reproducible methodology that can be presented to regulators and clients on demand

The challenge: price discovery for any given crypto asset is fragmented across 100+ exchanges globally. In the EU, only a defined subset of MiCA-compliant venues are available for compliant execution. Proving best execution requires 24/7 visibility into hundreds of order books — and the infrastructure to store and retrieve that data at scale.

July 1, 2026 is 103 days away. If your compliance infrastructure is not already being built, you are behind.

**COMPLaiNCE** helps crypto brokers and exchanges design and implement MiCA-compliant execution frameworks before the deadline.