What changed
The review reaches beyond implementation details
The targeted consultation opened on 20 May 2026 and, after an extension, is open until 30 September 2026. It will inform the Commission's reports under Articles 140 and 142 of MiCA and may support a future proposal to amend or complement the Regulation where the evidence warrants it.
The questionnaire examines cryptoasset classification, offers and white papers, asset-referenced and e-money tokens, reserves and redemption, the scope of regulated CASP services and administrative simplification. It also asks about DeFi, staking, lending and borrowing, NFTs and greater legal certainty for native on-chain assets.
Questions for the market
Where business evidence can shape the review
Product classification
Borderline and hybrid assets remain a practical issue where MiCA meets securities and other financial-services rules.
Stablecoin economics
The Commission is testing capital, reserve, redemption and multi-issuer models against market experience and global developments.
CASP service scope
Operators can explain where current service definitions fit or miss the way custody, execution, transfer and platform models work.
Activities beyond MiCA
The review explicitly seeks evidence on DeFi, staking, lending, borrowing and NFTs.
Business impact
Keep current authorisation plans moving
A consultation is the start of evidence gathering, not a change to the operating perimeter. CASPs, issuers and product companies should continue working from MiCA as it applies today, including current authorisation, prudential, custody, conduct and cross-border requirements.
The practical opportunity is to capture where the existing framework affects product design, capital use, cross-border scale or legal certainty. Evidence is more useful when it identifies a precise provision, describes the operational effect and proposes a workable solution. Firms considering a response should coordinate legal, product, treasury and operations rather than submit a policy view detached from the business model.
SKY7 view
Run the current framework and the reform watchlist in parallel
Management should separate two workstreams. The first is the live MiCA programme: authorisation, acquisition or provider integration under the current rules. The second is a focused reform watchlist covering only the consultation themes that could materially alter the planned product or economics.
This avoids delaying a viable 2026 route on the assumption that rules may change later. It also gives businesses a structured way to preserve evidence, respond to the consultation where useful and update the operating model when the Commission publishes conclusions or a legislative proposal.
Related SKY7 analysis
Keep the current MiCA route in view
MiCA framework for crypto operators
Review the live provider gate, service scope, prudential safeguards, custody and cross-border notification.
MiCA CASP authorisation tracker
Verify the legal entity, service scope and cross-border position against the current ESMA register.
EU MiCA CASP authorisation
See how SKY7 structures a direct Article 63 application around the applicant's intended operating model.
Primary evidence
Official sources
Sources checked .