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Brussels Reopens MiCA and the Window Shuts on 30 September

The European Commission’s targeted review of the Markets in Crypto-Assets Regulation closes at 23:59 CEST on 30 September 2026. Opened on 20 May, the exercise asks 86 questions about rules already operating under MiCA and products that remain partly or wholly outside it.

The deadline is an opportunity for crypto-asset service providers, issuers, banks and supervisors to put operational evidence into the Commission’s review. It is not an amendment to MiCA, and no rule changes on 30 September. Responses will inform reports due under Articles 140 and 142 by 30 June 2027, which may include a legislative proposal if changes are warranted.

Brussels originally set 31 August as the closing date. It later extended both the targeted exercise and a parallel public consultation by one month. The new deadline also collides with the opening of the UK’s crypto authorisation gateway, giving firms active on both sides of the Channel two separate regulatory processes to manage on the same day.

What the MiCA Review Is Actually Asking

The Commission split the exercise into two tracks. The public consultation seeks general views from citizens and organisations about digital assets. The targeted questionnaire is aimed at market participants and public authorities, including crypto firms, issuers, supervisors, central banks and finance ministries.

The targeted document is divided into four parts. The first covers crypto-assets other than asset-referenced tokens and e-money tokens. It asks about difficult classifications, white papers, marketing communications, the 14-day withdrawal right and potential administrative simplification. The examples include wrapped assets, governance tokens, synthetic exposures, tokenised fund interests and non-fungible tokens issued in a series.

The second part examines stablecoins. It covers reserve and redemption requirements, significance thresholds, third-country issuers and multi-issuer structures. One question asks whether MiCA’s prohibition on paying interest or other remuneration on asset-referenced and e-money tokens should remain or be permitted under conditions. Another asks whether the framework should continue to accommodate stablecoins issued by several entities.

The Extension Covers Both Consultation Tracks

The Commission’s 29 June extension notice says the consultation consists of a public component and a targeted component, and that “the consultation will now remain open until 30 September 2026.” That wording applies the extension to the full exercise, rather than to selected questions or one respondent group.

Brussels said digital-asset markets and the wider regulatory context were continuing to evolve, and that the extra month would give stakeholders more time to respond. It did not identify a company, industry association or government that requested the extension. Any claim that a particular lobby secured the additional month would therefore go beyond the Commission’s published account.

The dates also correct a potentially confusing distinction. A legal analysis published on 1 June discussed the new review, but the Commission opened it on 20 May. June is the month in which much of the outside analysis appeared, not the launch month.

Stablecoins, CASPs and Products Outside MiCA Are in Play

For crypto-asset service providers, the questionnaire goes beyond minor drafting adjustments. It asks whether MiCA’s list of regulated services remains adequate, whether appropriateness testing should extend to more services and whether the three minimum-capital classes of EUR 50,000, EUR 125,000 and EUR 150,000 remain suitable. It also seeks evidence on unauthorised non-EU firms serving EU clients, enhanced supervision of multifunction groups and whether European firms face undue restrictions when accessing global liquidity pools.

Those questions reach issues already visible in the market. FinanceFeeds has tracked the end of national transition periods, the cost burden reported by authorised firms and the expansion of the MiCA stablecoin register. The Commission is now asking for evidence that could distinguish one-off implementation pressure from structural defects in the regime.

The fourth section examines activities outside MiCA or only partly covered by it. The list includes decentralised finance, staking, crypto lending and borrowing, NFTs, prediction markets, tokenised deposits and perpetual futures. Questions test options such as certification for DeFi protocols, a separate staking framework, and whether prediction markets or perpetual contracts should sit under MiCA or existing securities law.

How to File a Response That Brussels Can Use

The Commission says only submissions made through its online questionnaire will be included in the consultation summary. Respondents do not need to turn every question into a position paper. A CASP can focus on authorisation, prudential capital, global liquidity and reporting, while a stablecoin issuer can concentrate on reserves, redemption, remuneration and cross-border structures.

A useful response should identify the relevant MiCA provision, describe the operational problem and support it with measurable evidence. Examples include the cost of duplicative reporting, capital tied up by a requirement, approval timelines across member states or liquidity lost because a venue cannot connect to a third-country pool. A concrete amendment is more usable than a general request for lighter regulation.

Respondents should also check the publication option attached to their filing and retain a copy of the submission. The Commission publishes responses according to the privacy choice made by the respondent, and consultation pages can change after a deadline passes.

MiCA Is Live While Brussels Reviews It

The review is taking place against an operating rulebook. ESMA says MiCA entered into force in June 2023 and most of its second-level and third-level measures now apply. Its interim MiCA register is updated weekly and includes authorised service providers, token issuers, white papers and non-compliant entities.

That register is also evidence of how implementation is moving. FinanceFeeds found in August that the register contained 329 records rather than 244, illustrating why date-stamped counts matter. ESMA also cautions that white papers appearing in the database have not been reviewed or approved by a national authority; responsibility remains with the issuer or offeror.

Firms therefore have to comply with the current text while arguing for a different future version. The consultation does not pause authorisation, disclosure, prudential or conduct obligations.

30 September Is Also the UK Gateway Date

The same date starts a separate clock in Britain. The FCA crypto licensing gateway opens at 9:00 a.m. on 30 September 2026 and closes at 11:59 p.m. on 28 February 2027, ahead of the mandatory UK regime taking effect on 25 October 2027.

The distinction is simple but operationally important. In the EU, 30 September is the last day to influence the review that may shape a later MiCA proposal. In the UK, it is the first day to apply for permission under a regime with fixed consequences for late applicants. A cross-border firm should not treat either filing as a substitute for the other.

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