Brussels aims to end regulatory fragmentation by proposing to transfer the supervision of crypto companies from member states to the ESMA, the European markets authority. This significant shift would profoundly transform the application of MiCA and bring the EU closer to a unified supervision model akin to a ‘European SEC’.
Harmonizing Supervision: Ambition for a Truly Integrated Single Market
According to the Commission, the vastly different approaches of the 27 EU countries regarding MiCA application threaten the coherence of the regulatory framework. By entrusting the supervision of crypto businesses to the ESMA, Brussels hopes to eliminate national divergences, streamline cross-border activities, and strengthen regulatory efficiency.
In its communication, the European executive states that ‘the EU financial markets remain fragmented, small, and uncompetitive,’ despite the scale benefits offered by a unified framework.
The proposals will still need to be debated and adopted by the European Parliament and Council.
Pressure Mounting: France, Austria, and Italy Were Already Calling for a Centralized Approach
In September, several national regulators, including AMF in France, FMA in Austria, and Consob in Italy, had raised concerns about the potential drift of a fragmented MiCA implementation. These authorities explicitly asked ESMA to assume a more central role.
The Commission’s initiative also responds to internal concerns: without harmonized supervision, MiCA could turn into a regulatory patchwork, undermining international actors’ confidence and complicating the European passport.
Towards an ESMA Closer to the SEC Model?
Currently, ESMA mainly coordinates national regulators rather than providing direct supervision, unlike the American SEC. Transferring ‘direct supervision competencies’ over crypto companies would be a structural change, bringing the European authority closer to a true single supervisor.
For the industry, the message is clear: the era of national experimentation with MiCA is coming to an end. Crypto companies operating in Europe may soon answer not to 27 regulators but to one.
A Decisive Step for European Competitiveness
If the reform is approved, it could offer the EU a strategic advantage. A centralized, clear, and homogeneous framework would attract more institutional players and strengthen European influence on international tokenization and digital market standards.
In a global race where the US is accelerating through the GENIUS Act and Asia is multiplying crypto licenses, Europe is now showing its determination to have an impact. Consolidated supervision could finally allow European markets to compete on equal footing.
The political task begins, but the direction is clear: the Union wants unified crypto regulation, and it wants it swiftly.
