Shaping the Future of Crypto Regulation

May 20 2024, Vienna

Insights from the MiCA Roundtable in Vienna

The third event in this series took place on May 20, 2024, in Vienna. This roundtable, held in cooperation with the European Commission and sponsored by Crystal Intelligence, AML Incubator and Bitpanda, brought together a diverse group of experts to discuss key issues related to the implementation of MiCAR.

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MiCAR Roundtable Expert Series

Key Highlights

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.

Primary Calls to Action


Establish clear guidelines for CASP compliance and third-party whitepapers. Develop risk disclosure policies and support mechanisms for CASPs as well as standardize the interpretation of MiCA provisions across all EU languages and jurisdictions for consistent compliance.


Develop precise criteria for decentralization, focusing on control and influence within the ecosystem. Standardize regulatory approaches and engage with technological developments.

Reverse Solicitation

Define non-solicitation criteria and enhance the supervisory framework. Provide clarity on third-country listings and issuer liabilities.

Market Abuse

Clarify market abuse requirements and “Admission to Trading” definitions. Establish monitoring and reporting protocols and provide guidance on handling Suspicious Transaction and Order Reports (STORS).


Provide detailed guidelines on the scope of grandfathering. Implement provisional measures for stablecoins and EMTs/ARTs. Implement a clear transitional process for MiCAR compliance with defined criteria for grandfathering and crypto-asset listings.


By fostering these expert discussions and implementing the recommended actions, the MiCAR Roundtable Series aims to enhance the regulatory framework for crypto-assets, promoting stability, transparency, and innovation in the digital finance sector. For more information and to participate, please contact the organizers at or