Europe is entering a new phase of its crypto regulation. The debate is no longer about the need to regulate the sector. It now concerns a more sensitive question: who should really hold the wheel, Brussels or the national authorities?
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In brief
- Europe wants to tighten crypto supervision without breaking MiCA’s momentum.
- ESMA is gaining ground, but States refuse to step aside too quickly.
- The real issue is political: better control without killing the attractiveness of the market.
A crypto debate that is changing in nature
The real issue has now been raised. The European Commission has proposed transferring to ESMA part of the supervision of large crypto providers, until now exercised by national authorities. This approach is part of a broader desire to extend the powers of ESMA. In other words, Europe wants to test more direct surveillance for the most important players.
This shift does not happen by chance. MiCA has created a single framework for crypto-assets in the European Union, with common rules for issuers and service providers. The text has been applied since December 30, 2024 for the actors concerned.
In this model, an authorization obtained in one Member State then allows operation elsewhere in the Union via the European passport. It’s convenient for businesses. But this quickly transforms a national decision into a continental issue.
Why some countries want more ESMA
France, Austria and Italy have taken a position from September 2025. Their market authorities believe that the first months of MiCA have already revealed strong differences in practice between countries. For them, this heterogeneity weakens the single crypto market.
The tipping point is also the examination carried out by ESMA on an authorization granted to Malta. The European regulator welcomed the resources and cooperation of the Maltese authority, while judging that certain material points had not been fully resolved and that certain risk areas had not been sufficiently assessed.
For supporters of centralization, the message is simple. If a single national license opens the doors to the entire European market, then control must be more homogeneous. Otherwise, the risk of regulatory forum shopping becomes real, and investor protection varies too much depending on the country of entry.
Why Malta refuses to give in too quickly
Malta, for its part, does not say no to any development. Above all, she says that the calendar is bad. According to the MFSA, it is premature to disrupt the supervision architecture while the real impact of MiCA on the market and on its players is still being evaluated.
This line is not just national defense. Opponents of too rapid centralization argue that a sector as fluid as crypto needs proximity, land and accumulated expertise. Supervision that is too distant can become more uniform on paper, but less detailed in reality.
Another more technical criticism: the risk of a regulatory puzzle. If the ESMA supervises one part, the national authorities keep other elements, and the AMLA also intervenes on certain subjects, the overall reading of the risk can become fragmented. However, the logic of DORA pushes rather towards an integrated vision.
The real strategic choice for crypto Europe
Basically, Europe must choose between two promises. The first is that of a more unified crypto market, more readable and better defended against regulatory arbitration flaws. The second is that of national sovereignty which retains flexibility and responsiveness.
The most likely is not a total switchover, but a hybrid model. Truly systemic and very cross-border crypto players could fall more under ESMA. The others would remain under national control, with stricter convergence requirements. This is the most coherent path if the EU wants to avoid an unnecessary institutional shock.
One thing is already clear: the future of the European crypto market no longer depends only on the content of MiCA. It also depends on those who will be responsible for implementing it. And on this point, Europe plays much more than a simple administrative debate. It highlights its credibility, its competitiveness and its ability to supervise innovation without stifling it. Meanwhile, Charles Schwab led the way in purchasing Bitcoin and Ethereum.
