The discussion on decentralization, led by Alexander Harutunia, emphasized the absence of a formal definition for “decentralization” in MiCAR, presenting a risk of varied interpretations. Participants focused on centralization vectors, such as smart contract access, Web2 interfaces, and platform dependence, highlighting the need for clear regulatory guidance. The roundtable called for rigorous research into decentralization and the development of comprehensive regulatory guidelines.

During the discussion on reverse solicitation, led by Hedi Navaza, the significance of this topic in regulating interactions between EU clients and third-country crypto-asset service providers was thoroughly explored. The participants highlighted the complexities of token listings by EU-based issuers on third-country exchanges and emphasized the need for clear guidelines from ESMA.

The discussion on the requirement for crypto-asset whitepapers, led by Oliver Völkel, focused on the obligations of offerors and CASPs under MiCAR, particularly regarding the publication and use of whitepapers. Key issues included the intersection of requirements for CASPs and offerors, as well as the challenges posed by language discrepancies in MiCAR’s text. Participants emphasized the need for explicit guidelines for CASPs in the absence of whitepapers, the definition of parameters for third-party whitepapers, and the issuance of directives on risk disclosure.

Philipp Bohrn led an examination of the complexities surrounding the application of grandfathering provisions for CASPs under Austria’s national laws transposing MiCAR. The discussion highlighted key issues, including ambiguities in how services under AMLD5 translate into MiCAR services and the urgent need for Austria to adopt national laws promptly. Participants emphasized the necessity of issuing comprehensive guidelines on the scope of grandfathering, establishing simplified transitional procedures, and defining criteria for assessing crypto-asset listings as well as the implementation of provisional measures for stablecoins and ARTs.

During the session led by Romena Urbonaite, the challenges posed by MiCAR’s requirements for market abuse monitoring and inside information disclosure, inspired by MAR, were thoroughly addressed. The discussion highlighted key issues, including the broad application of market abuse requirements and the need for clear definitions of relevant market participants. Participants emphasized the importance of clarifying the scope of market abuse requirements, defining the term “admission to trading,” and establishing protocols for monitoring and reporting suspicious transactions.