Key takeaways

• Europe is leading on crypto regulation with MICA, but the UK is leveraging its second-mover advantage to design a more flexible framework.
• Stablecoins are now the backbone of the crypto market, but regulatory clarity is urgently needed to safeguard liquidity and prevent systemic risk.
• Tokenization is taking off, offering new liquidity paths - but clarity is still needed on where it fits within existing financial rules.
• DeFi presents regulatory challenges, especially around identifying who is responsible when decentralization is partial or unclear.
  
  

Panelists

• Antoine Scalia, CEO – Cryptio  (moderator)
• Stefan Tomanek, Head of Unit Financial Innovation Supervision – FMA Austria
• Charles Moussy, Director, Head of Innovation & Digital Finance – AMF France
• Matthew Osborne, Policy Director, Europe – Ripple

MiCA: the EU’s first-mover advantage

The panel opened with a deep dive into MICA, the EU’s landmark crypto regulation. Charles Moussy traced its roots to early French experimentation with national frameworks, noting how France’s optional licensing system for crypto asset service providers (CASPs) paved the way for a comprehensive EU-wide regulation.

“Crypto is by nature cross-border. It made no sense to regulate it nationally.” – Charles Moussy, AMF

MICA (Markets in Crypto-Assets Regulation) became the world’s first unified regulatory framework covering crypto services across all 27 EU member states. It defines obligations for stablecoin issuers, trading platforms, and wallet providers, aiming to foster clarity and consumer protection while enabling innovation.

Stefan Tomanek shared Austria’s approach, emphasizing a shift from reactive to proactive supervision post-5th AMLD (Anti-Money Laundering Directive). Unlike the fragmented national licensing environment of the past, Austria established a dedicated crypto unit and developed one of the most detailed MiCA authorization guides to date.

“Our learning from the fifth AMLD was that we have to change our approach… from being reactive to being proactive.” – Stefan Tomanek, FMA

As the regulatory landscape continues to evolve, panelists hinted at what may come next: MiCA II. This anticipated second phase is expected to address areas left out of the initial regulation, most notably decentralized finance (DeFi), staking, and NFTs. The first version of MiCA intentionally avoided fully regulating these complex and fast-changing sectors. MiCA II aims to close that gap.

UK’s tailored, second-mover strategy

Matthew Osborne praised MiCA as a “great achievement,” but noted that the UK’s regulatory delay created a strategic advantage - the ability to observe what worked and what didn’t in other jurisdictions.

The UK’s proposed framework takes a principles-based and outcomes-focused approach, a philosophy borrowed from its traditional financial regulation. Unlike MiCA’s prescriptive, rules-heavy model, the UK model sets broad goals (such as market fairness and financial stability) and gives firms more flexibility in how to meet them.

“London should be a center for digital assets. The UK is taking a principles-based, outcomes-focused approach, unlike MICA’s detailed, prescriptive model.” – Matthew Osborne, Ripple

Osborne also pointed to stablecoins as a major point of divergence. MiCA mandates that stablecoins must be issued, backed, and regulated within the EU - a policy designed to protect EU consumers and monetary sovereignty. In contrast, the UK allows overseas-issued stablecoins to circulate under certain conditions, making it easier for international firms to operate in London. This openness could position the UK as a global hub for cross-border digital asset flows.

Stablecoins: infrastructure, not just innovation

All panelists agreed - stablecoins are no longer just experimental assets. They are foundational market infrastructure. They enable liquidity, on-chain settlements, and cross-border transactions with low latency.

“Stablecoins are the core liquidity tools of how whole markets function. If there’s no clear rule guaranteeing the peg, the whole crypto market could collapse.” – Charles Moussy, AMF

The scale of this infrastructure is significant. As of mid-2025, the total market capitalization of stablecoins globally exceeds $250 billion - with USD-backed stablecoins like USDT and USDC dominating over 95% of the volume. In comparison, euro-backed stablecoins remain small, totaling only $200–300 million, but their market share has been growing rapidly in percentage terms as European regulation like MICA begins to provide clearer frameworks.

Matthew Osborne added that with their peer-to-peer design and global reach, stablecoins pose both opportunities and regulatory challenges. He highlighted the multi-issuance model - a structure where a stablecoin is issued across multiple jurisdictions, with reserves split accordingly. This model, already used by Circle’s EURC in France, allows for local compliance without fragmenting international utility.

Still, panelists agreed - broader adoption is held back by regulatory uncertainty. Should more EU regulators adopt the model? Will they allow multiple reserve locations? These open questions must be resolved before stablecoins can safely scale.

Tokenization: legal clarity still lags

Tokenization, whether of real estate, funds, or precious metals, was framed as a powerful tool to create liquidity for illiquid assets. But the challenge lies in the regulatory fit.

“If you have an illiquid asset, tokenization can create liquidity. But without legal clarity, these projects often fall through.” – Stefan Tomanek, FMA

Many tokenized assets fall under existing securities laws, such as MiFID or AIFMD, depending on how they’re structured. This creates complexity for both startups and regulators. In Austria, for instance, tokenized real estate projects collapsed not due to technical failure, but because they clashed with legacy fund manager regulations.

Charles noted the EU’s DLT Pilot Regime, designed to allow limited experimentation with blockchain-based financial infrastructure, hasn’t seen wide adoption. He and his Italian counterparts are pushing for a refresh - more flexibility, dynamic thresholds, and an easier path to scale.

Meanwhile, the UK’s Digital Securities Sandbox (DSS) lets firms increase their level of activity as they demonstrate regulatory maturity. This “graduated compliance” model was seen as a more commercially viable path for innovation.

DeFi: still a grey zone in regulation

Finally, the panel tackled decentralized finance (DeFi) - a space that regulators globally continue to struggle with. The issue isn’t whether DeFi should be regulated, but how.

“You can’t supervise something if there’s no identifiable subject. But in practice, most DeFi protocols are not fully decentralized.” – Stefan Tomanek, FMA

Stefan and Charles both pointed out that most DeFi protocols still rely on centralized components - admin keys, token-weighted governance, oracles, and hosted front-ends. These are potential points of accountability.

MiCA currently excludes truly decentralized applications from its scope. However, many regulators believe that most DeFi systems are only partially decentralized, meaning they could still fall under regulation. This grey area is one of the primary motivations for the expected MiCA II, which will likely introduce clearer guidelines on if - and how - DeFi operators should be regulated.

Charles also raised the possibility of industry standards for smart contract audits as a way to assess protocol reliability without direct oversight. As DeFi matures, such hybrid approaches may bridge the gap between innovation and investor protection.

Regulation is now driving the market

As Antoine Scalia remarked in his opening, we’re past the “meme phase” of regulatory clarity. The frameworks are arriving, institutions are engaging, and the tools to enable back-office, reporting, and audit-readiness are finally in place.

“There’s an amazing opportunity to build a better system—one with financial integrity at its core.” – Antoine Scalia, Cryptio

With Europe setting the pace and the UK experimenting with flexible models, the panel made one thing clear - crypto’s future will be as regulated as it is innovative, and that’s how it scales.

About Cryptio

Cryptio is the leading financial data platform for tokenization compliance, crypto accounting and lending. Trusted by over 450 clients - including publicly listed companies like Circle, Exodus, Bitcoin Depot and Semler Scientific, leading crypto-native organizations like Uniswap Labs, World, and MetaMask, and partnered with Big4 audit firms like KPMG and Deloitte, Cryptio delivers an enterprise-grade data layer that translates complex on-chain activity into auditable, GAAP and IFRS-ready records.

Explore how Cryptio can transform your financial integrity and scalability today.

Book a demo.