Our Input to the European Commission’s Review of MiCA

Eunice AI has provided input to the European Commission's review of the MiCA regulation, drawing on what we've learned supporting clients through the white paper process (and spending a lot of time deep in the interim register).

There were three items in particular that shaped our response:

Decision-useful disclosure. We'd welcome reorienting white papers towards a core set of disclosures that holders can readily compare and act on.
Clarity on when to update. The Article 12 trigger is well framed. Our view is that non-exhaustive guidance on events that may trigger an update, informed by our work in the FCA's Regulatory Sandbox, would help it work in practice.
Supporting the register as it develops. The interim register is still being built out, so we shared some practical input from our day-to-day use of it. A few usability improvements could help CASPs answer the questions they ask of every entry: is there more than one white paper for this asset, who is responsible for it, does it carry the expected identifiers, and is the document itself available?

MiCA gave the EU a bespoke framework for crypto-assets, shaped by the circumstances in which it was designed. The review is a chance to assess how well it works in today's landscape. We'll keep supporting firms through the white paper process as it evolves, and would be glad to contribute further as the review progresses (special thanks to the brilliant Ana Beslija and Sophie Soh for leading the charge!).

Originally posted on LinkedIn by Chrislyn Pereira.