Global regulatory frameworks advanced in parallel. 2025 23 12

Global regulatory frameworks for crypto-assets moved forward significantly in the mid‑2020s, with Europe and the United Kingdom setting out some of the most comprehensive models. The EU’s Markets in Crypto‑Assets Regulation (MiCA) and the UK’s planned regime both aim to bring crypto under rules comparable to traditional finance, especially around consumer protection, market integrity, and financial crime controls.​

MiCA across the European Union

MiCA entered into force in June 2023 and is being phased in, with stablecoin rules (for asset‑referenced tokens and e‑money tokens) applicable from mid‑2024 and the broader framework for all crypto‑asset service providers fully applicable from late 2024. It harmonizes licensing, conduct, and disclosure standards across the 27 EU member states, creating a single passportable regime for crypto‑asset service providers (CASPs).​

MiCA also imposes strict requirements on stablecoin issuers, including reserve management, redemption rights, governance, and enhanced supervision for significant tokens by the European Banking Authority. CASPs must implement robust AML/KYC frameworks, comply with the EU’s Travel Rule via the Transfer of Funds Regulation, and monitor for market abuse such as insider trading and manipulation.​

UK roadmap to a 2027 crypto regime

The UK, outside the EU, has chosen to build its own comprehensive crypto regime via secondary legislation and Financial Conduct Authority (FCA) rulemaking. In December 2025 the government and FCA confirmed that the new regime is expected to fully commence around late 2027, with consultation papers CP25/40–42 detailing rules on regulated crypto activities, market abuse, and prudential standards.​

The UK explicitly follows a “same risk, same regulatory outcome” principle: crypto activities that pose similar risks to traditional financial services must meet equivalent standards on disclosure, governance, capital, and consumer protection, including for stablecoin issuance and custody services. Together, MiCA and the UK framework signal that major jurisdictions are moving from fragmented national rules toward full‑scale, risk‑aligned regulation of crypto markets.