MiCA Is Now the Global Compliance Benchmark. Even If You Are Not in Europe.
62% of all MiCA white paper filers are offshore entities seeking EU market access. With Article 78 best execution obligations taking effect July 1 and AMLR 27 treating CASPs as credit institutions, MiCA is no longer just a European concern.
Monday, 23 March 2026
Share:
The data from the first full quarter of MiCA enforcement is unambiguous: 62% of all MiCA white paper filers are offshore entities — BVI, Switzerland, Cayman Islands — seeking EU market access through the passporting framework. Ireland and Malta have emerged as the primary access jurisdictions.
This tells you something important: MiCA is not a European regulation. It is the global compliance benchmark for any business that wants institutional capital, banking relationships, or access to the EU's 450 million consumers.
The practical implications for Q2 2026:
**Article 78 best execution obligations take effect July 1.** That is 100 days away. If you have not started building your best execution policy, order routing documentation, and 5-year record retention infrastructure, you are already behind.
**The EBA's February 12 opinion creates a dual-licensing requirement** for platforms handling e-money tokens (EMTs). If your crypto casino or exchange settles in USDC or EURC, you may need both a CASP licence and an EMI licence.
**MiCA's AML provisions now sit alongside AMLR 27**, which treats CASPs as equivalent to credit institutions for AML purposes. The combined compliance burden is substantial.
At COMPLaiNCE, we help businesses build MiCA-compliant architectures from the ground up — whether you are applying for a CASP licence in Gibraltar, Spain, or Malta, or structuring a tokenisation programme under the DLT Pilot Regime.