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ARTICLE · 13 OCTOBER 2026

MiCAR 2.0: Examining The EBA And ESCB Responses

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The European Banking Authority and European System of Central Banks have published responses to the Markets in Crypto-Assets Regulation consultation that signal a fundamental shift in EU digital finance architecture. Rather than expanding MiCAR's scope, regulators are focusing on repairing critical interfaces between crypto regulation and traditional financial services, addressing stablecoin liquidity, bank issuance models, group supervision, and the private-law treatment of tokens.

European UnionFinance and Banking
Michael Huertas
Michael Huertas
Hagen Weiss
Hagen Weiss
Fabian Joshua Schmidt
Fabian Joshua Schmidt
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EU RegCORE Client Alert | EU Digital Single Market, financial services and crypto-assets

The first review of the EU's Markets in Crypto-Assets Regulation (MiCAR) is no longer a narrow post-implementation clean-up. Read together, the September 2026 published responses to the MiCAR consultation from the European Banking Authority (EBA) and from the European System of Central Banks (ESCB) point toward a second-generation EU digital-finance architecture.1 The common direction is not to bring every tokenised activity inside MiCAR. It is almost the opposite: preserve technological neutrality and the sectoral rulebook, while repairing the interfaces that are beginning to matter commercially—stablecoin liquidity, bank issuance models, third-country multi-issuance, group supervision, crypto lending, tokenised deposits, settlement and the private-law treatment of tokens. 'MiCAR 2.0' is used here as shorthand for that review process, not as the name of an existing legislative proposal.

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