MiCA explainer

MiCA Review 03.09.2026: Consultation until 30.09.

Regional Segment Explanation: No new clearly dated events in the last 24 hours, so we're focusing on the European Commission's MiCA review consultation, with a response deadline of 30 September.

Toms Ābeltiņš

3 September 20267 min read

No new clearly dated events in our segment over the last 24 hours. We offer an explanation of the European Commission's consultation on the MiCA regulation review: opened on 20 May, with the response deadline extended to 30 September 2026. What this means for regional CASPs, cards, wallets, and tax tools.

Wednesday, 3 September 2026. This is an explanatory publication (MiCA explainer) rather than a daily news update. Over the last 24 hours, there have been no new, clearly dated significant events in our segment - crypto exchanges and CASPs, hardware wallets, crypto cards, and tax tools serving the Baltics (LV, LT, EE) and Northern Europe (FI, SE, NO, DK). Furthermore, no new, previously unreported regional event has emerged in the past week that warrants being presented as fresh news. Therefore, today we are focusing on an ongoing, yet timely, topic: the European Commission's targeted consultation on the MiCA regulation review, for which the response submission deadline is approaching. Dates and facts are provided below with precise references; interpretations of what might change are labelled as expectations, not as determined outcomes.

Why this topic now

The reason we are highlighting this topic today is the calendar, not a new event. The European Commission opened the targeted consultation on the MiCA regulation review on 20 May 2026, with an initial response deadline of 31 August 2026. The deadline was later extended to 30 September 2026 (23:59 Central European Time). This means that regional market participants wishing to express a position have less than a month left. This is a typical 'preparing for a deadline' situation: the event itself is not yesterday's news, but its practical relevance is high right now.

We emphasise that the opening of the consultation in May and the extension of the deadline are not events of the last 24 hours. We present them as context with precise dates, rather than as fresh news.

What is the MiCA review consultation

The consultation is part of the review mechanism already provided for in the MiCA regulation. Articles 140 and 142 of the regulation mandate the European Commission to prepare a report on how the regulation is working in practice, and the consultation responses are one of the main inputs for this report. In the consultation document, the Commission asks whether MiCA 'remains fit for purpose, taking into account its initial implementation and market and policy developments since its application began'.

The consultation is targeted, not general: it is addressed to specialised participants, including crypto-asset service providers (CASPs), crypto-asset issuers, and public authorities such as national and European supervisors, central banks, and finance ministries. In practice, this means that responses are most likely to be submitted by industry organisations, major service providers, and supervisors, not individual users.

The results of the consultation are not directly binding. They will feed into the Commission's report, and only then - if the Commission deems it justified - could legislative proposals follow, informally referred to in the industry as 'MiCA 2'. The final report to the European Parliament and the Council is expected by 30 June 2027. In other words, this is early-stage policymaking, not a ready set of rules; any actual changes are several years away.

Key topics covered by the consultation

The consultation document and its legal analysis point to several areas directly relevant to our segment.

Firstly, scope and definitions. Consideration is given to how to distinguish crypto-assets that qualify as financial instruments (and thus remain under sectoral regulation) from those covered by MiCA. Hybrids, such as tokenised fund units, are mentioned as problematic.

Secondly, stablecoins - asset-referenced tokens (ARTs) and e-money tokens (EMTs). Issuer capital requirements, the prohibition of interest payments on stablecoins, and possible equivalence frameworks for global stablecoins are discussed. The analysis indicates that after almost two years of the regulation's operation, no asset-referenced token (ART) has been licensed in the European Union - this in itself is a signal that this part of the regulation may be reviewed.

Thirdly, crypto-asset service providers (CASPs). Adjustments to the prudential regime and a possible alignment with the requirements for investment firms are being considered. This is the part of the consultation that most directly affects regional exchanges and service providers.

Fourthly, areas outside the current scope: decentralised finance (DeFi), including questions about CASP obligations to assess associated protocols and potential smart contract certification schemes; staking, lending, and borrowing; as well as NFTs and the private law status of tokens (ownership, custody, pledge, insolvency). These are precisely the frontier areas where regulation is currently most uncertain.

What this means for our segment in the Baltics and Nordics

The impact on our four categories is uneven, and it is important to state this honestly, without embellishment.

Crypto exchanges and CASPs are at the direct centre of the review. Regional exchanges that have already received or are still applying for a MiCA CASP authorisation are precisely the audience to whom the consultation is addressed. Potential changes to the CASP prudential regime and scope definitions may affect both capital requirements and which services fall under MiCA at all. These firms have the greatest motivation to submit a response by 30 September or at least follow the positions of industry organisations.

MiCA indirectly affects the crypto card segment - mainly through EMT and stablecoin rules. Card products based on e-money tokens or stablecoin settlements depend on how issuer requirements will be clarified; changes to the interest prohibition and reserve rules may affect card economics.

Hardware wallets and self-custody are mostly outside the scope of MiCA: manufacturers of non-custodial devices, such as Ledger, Trezor, BitBox, Coldcard, and Tangem, do not provide crypto-asset services in the sense of MiCA. However, the DeFi and self-custody sections of the consultation are worth watching, as they touch upon the broader question of where regulated service ends and the user's own responsibility begins. We clearly state: currently, this is a conceptual, not a practical, issue for this category.

Tax tools (Koinly, Blockpit, Divly, etc.) are not directly subject to MiCA - they are not CASPs. Their regulatory environment is rather related to tax reporting frameworks, not MiCA. The review affects them only indirectly, to the extent that the data available on transactions and service providers changes.

Context: Regional CASP landscape (for reminder, not fresh news)

These points are not news from the last 24 hours; we include them for background with previous dates. According to publicly available summaries, in early July 2026, approximately 38 companies in the Nordics and Baltics had received MiCA approval, of which about 35 were pure CASPs; the distribution was uneven, with Latvia and Norway as the most active regional jurisdictions and Estonia, where the first individual MiCA authorisation was issued only in the summer. The growth rate of the regional CASP register and the fact that the net growth in the ESMA register is driven mainly by credit institutions outside the region were discussed in more detail in a separate explanation on 22 August. These figures are context, not today's event, and may have changed since the last public updates.

Watchlist and next checkpoints

MiCA review consultation: the nearest and most specific deadline is the submission of responses by 30 September 2026. After that, we follow the preparation of the Commission's report and any indications of possible legislative proposals; the final report is expected by 30 June 2027.

Regional authorisation process: we follow the appearance of new Baltic and Nordic firms in the ESMA MiCA register and the status of Norwegian exchanges (Firi, K33, NBX, Bare Bitcoin, Tyr Markets) after the end of the transition period.

Stablecoin section: we observe whether, after the consultation, there are signals of changes to ART and EMT requirements that could affect regional card and payment products.

If any of these points materialise with a clear date and within a 24-hour window, we will return to the classic daily review format.

Practical steps for market participants

For regional exchanges and CASPs, as well as card and payment service providers affected by EMT rules, the practical step is to assess whether to submit their response to the consultation by 30 September, either directly or through industry associations. Even if a firm does not plan to submit a formal response, it is worth familiarising itself with the consultation document to understand in good time which potential changes would directly affect its operations - especially in the CASP prudential regime and scope definitions.

For hardware wallet and tax tool users, this review currently does not necessitate direct action; it is a topic for observation, not action. As always, the fundamental principles of self-custody security - updating firmware from official sources and protecting the seed phrase - remain unchanged regardless of the regulatory direction.

Overall, the most important conclusion is that the MiCA review has begun but is far from complete. Any actual changes are several years away, and until the final report in 2027, the current rules remain in force. The nearest specific date to mark on the calendar is 30 September 2026.

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