ESMA's June 2025 MiCA Q&As Three Silent Game-Changers Every Crypto Platform Must Internalise

1 Why an apparently modest Q&A-batch rewires entire operating models

Compliance officers who skim regulatory updates only for headline-worthy acronyms may have overlooked three slim yet densely reasoned answers that the European Securities and Markets Authority published in mid-June 2025; taken together, they redraw the perimeter of lawful custody, trading-venue architecture and client-rights facilitation under Regulation (EU) 2023/1114 (MiCA).

2 Custody segregation: "separate address" now means really separate

ESMA confirms that a crypto-asset service provider (CASP) holding assets for clients must use wallet addresses that are entirely distinct from every address to which proprietary coins are sent, and that intermingling client assets with those of sister companies—however commercially convenient—introduces conflicts so severe that they may breach Articles 72 and 75 MiCA unless exhaustively mitigated. Beyond physical segregation, CASPs must publish