France, Austria, and Italy’s top financial watchdogs have called for Brussels to centralise supervision of major crypto firms, warning that patchy enforcement of the EU’s Markets in Crypto-Assets (MiCA) regulation risks undermining investor protection.
In a joint paper published on Monday, France’s Autorité des Marchés Financiers (AMF), Austria‘s Finanzmarktaufsichtsbehörde (FMA) and Italy’s Commissione Nazionale per le Società e la Borsa (CONSOB) urged the European Securities and Markets Authority (ESMA) to take direct control of overseeing large crypto-asset service providers.
Limited convergence
“Supervisory convergence between national authorities quickly reaches its limits,” the regulators said, citing “major differences” in how countries apply Markets in Crypto-Assets (MiCA). The regulatory framework rolled out in full in late 2024.
The plea follows scrutiny of Malta’s Financial Services Authority (MFSA), which licensed several global exchanges—including OKX, Gemini and Crypto.com—under MiCA. A June ESMA review flagged shortcomings in Malta’s approval of one unnamed firm, noting unresolved “material issues” when the licence was granted. In March, North Korean hackers used OKX to launder $1.5bn stolen from Bybit, prompting regulators to push ESMA and the MFSA for action, including revoking OKX’s EU access.
(ESMA) concluded it was a good time to reconsider more EU-level supervision. — European Securities and Markets Authority quoting its own year-old document in response to this week’s complaint
ESMA, tasked with harmonising MiCA enforcement, told Bloomberg it was “working intensely on ensuring convergence in the authorisation and supervision” of crypto providers. A spokesperson added that the watchdog had already “concluded it was a good time to reconsider… more EU-level supervision” in a 2024 paper (published before the full rollout of MiCA). ESMA did not immediately reply EU Perspectives‘ question as to what the reconsideration might practically involve in order to ameliorate the situation.
Security means confidence
The three national regulators, however, argued that only centralised oversight could prevent firms from forum-shopping for lax jurisdictions. “This would be the only way to avoid opportunistic choices between countries,” they wrote, proposing ESMA mimic the EU’s banking supervisory mechanism.
Their four-part plan demands stricter rules for non-EU platforms targeting European investors. “Any intermediary executing orders on crypto-assets should do so on a platform that complies with MiCA or equivalent regulations,” the paper stated, suggesting the European Commission assess third-country equivalence. For cybersecurity—a critical concern after the OKX breach—they mandated independent audits before licensing and periodic renewals. “This measure would ensure greater security… and boost investor confidence,” the regulators argued.
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Token offerings also drew fire. The AMF, FMA and CONSOB proposed a “single access point” managed by ESMA for filing whitepapers, replacing today’s fragmented national systems. “Centralisation would simplify the process for issuers and avoid market fragmentation,” they said, excluding stablecoins from the scheme. Without such fixes, they warned, Europe’s crypto framework risks becoming a “threat” to both investor safety and homegrown firms’ competitiveness.
Cracks and loopholes
MiCA, adopted in 2023, aimed to harmonise crypto rules across the bloc by requiring firms to secure a single licence for EU-wide operations. Its architects touted consumer protections—from anti-money laundering checks to transparency rules—as a model for global regulation. But as the AMF, FMA and CONSOB made clear, divergent enforcement has exposed cracks. “The current approach limits the effectiveness and scope of supervision,” they said, urging Brussels to “strengthen the competitiveness of European players” by closing loopholes.
The current approach limits the effectiveness and scope of supervision. — position paper by Italian, French, and Austrian financial watchdogs
Whether ESMA gains new powers remains uncertain. For now, the watchdog’s spokesperson stressed that “convergence” efforts are ongoing. But with crypto’s cross-border nature straining national regulators’ capacities, the push for a pan-European cop on the beat seems poised to shape MiCA’s next phase—and Europe’s bid to lead the crypto rulebook race.
