The European Commission is asking whether the EU’s Markets in Crypto-Assets Regulation (MiCA) remains fit for purpose after its first period of implementation. Its targeted consultation reaches beyond adjustments to the existing rules: it asks how the EU should approach stablecoins, crypto-asset service providers, decentralized finance, staking, lending, and legal rights in tokenized assets.

The deadline is Wednesday, September 30, 2026, at 23:59 CEST. The Commission extended the original August 31 deadline once. Responses must be submitted through its online questionnaire.

Why This Consultation Matters

MiCA created a common EU framework for crypto-asset issuers and service providers. Its stablecoin provisions began applying in June 2024, and the remaining provisions followed in December 2024. The Commission is now testing how that framework works in practice, where its boundaries remain uncertain, and whether market developments call for changes.

The targeted consultation contains 86 numbered questions. The answers will inform the Commission’s review of MiCA, including a report on its application due by June 30, 2027. That report may be accompanied by a legislative proposal where the Commission considers one appropriate. A question in this consultation is therefore an invitation for evidence and policy views, not an adopted rule or a proposed amendment.

Stablecoins: Reserves, Redemption, and Global Issuance

A substantial part of the questionnaire examines asset-referenced tokens and e-money tokens, MiCA’s two principal stablecoin categories. The Commission asks about their potential use in payments and settlement, the calibration of issuer capital and reserve requirements, liquidity, redemption rights, and safeguards during periods of stress.

It also examines multi-issuance models, in which related issuers operate a global stablecoin across jurisdictions. The questions probe whether those models should remain possible under MiCA and whether reserves held across entities and countries could be moved quickly enough to meet EU redemptions during a crisis. For issuers and firms building cross-border payment products, the answers could shape the next debate over how global stablecoin arrangements operate in the EU.

CASPs: What Services Should MiCA Cover?

For crypto-asset service providers, the Commission asks whether MiCA’s current list of regulated services adequately reflects the market and gives businesses sufficient clarity. It also seeks feedback on whether requirements can be simplified or made more proportionate. These questions matter to platforms and intermediaries designing products that may combine custody, trading, execution, or other services.

The consultation draws a boundary here: CASP supervision itself is outside this questionnaire’s scope, because supervisory arrangements are being addressed through a separate market integration and supervision initiative. Respondents should distinguish questions about which activities MiCA regulates from questions about which authority should supervise a provider.

DeFi: Where Does Decentralization End?

MiCA does not treat every on-chain activity alike. The review asks how policymakers should assess decentralized finance and, in particular, when an identifiable person or group retains enough control over a protocol to justify regulatory obligations. The questionnaire points to factors such as administrative keys, upgrade authority, concentrated governance power, custody of user assets, and the presence of an intermediary providing a crypto-asset service.

It also explores potential certification approaches for DeFi applications and smart contracts. These are options on which the Commission is seeking views; no certification requirement has been adopted through this consultation. Protocol teams, developers, DAO participants, and service providers have an opportunity to explain how governance and technical controls work in practice, rather than leaving those questions to be answered solely in abstract terms.

Staking, Lending, and Tokenized Rights

The Commission separately asks whether staking should continue without a dedicated MiCA service category and whether crypto-asset lending and borrowing should be regulated. The questionnaire notes an important distinction: although staking is not separately regulated as a service, a provider that holds clients’ crypto-assets or keys may already need authorization to provide custody and administration under MiCA.

The review also reaches questions that go beyond licensing. It asks about legal certainty over ownership and transfer of tokens, rights against third parties, the use of tokens as collateral, custody chains, and treatment in insolvency. Those questions are especially relevant to tokenized asset projects whose commercial promise depends on whether an on-chain record creates rights that can be recognized and enforced off-chain.

What Stakeholders Should Do Before the Deadline

The Commission says respondents may answer only the questions relevant to them and encourages clear explanations supported, where possible, by data, concrete examples, legal references, and suggested solutions. A focused submission identifying a specific operational problem and a workable change can be more useful than a general position on all 86 questions.

Issuers, CASPs, protocol teams, financial institutions, and other affected stakeholders should review the targeted consultation and questionnaire and submit any response by 23:59 CEST on September 30, 2026. The rules have not changed as a result of this consultation, but the evidence submitted now may influence what the Commission proposes next.

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This blog post is for informational purposes only and is not legal advice. Please consult with a Launch Legal attorney regarding your specific situation.