MARKETS IN CRYPTOASSETS

 

A. INSTRUCTIONS/APPLICATION TEMPLATES

 

 

B. Announcements by the Hellenic Capital Market Commission (HCMC), ESMA, EBA & EIOPA

Markets in Crypto-Assets Regulation (MiCA)

ESMA’s webpage: https://www.esma.europa.eu/esmas-activities/digital-finance-and-innovation/markets-crypto-assets-regulation-mic

 

C. REGULATORY FRAMEWORK

 

i. PRIMARY LEGISLATION

 

 

ii. SECONDARY LEGISLATION

#

MICA-Article

Description

Reference

Date

 

 

TITLE II - CRYPTO-ASSETS OTHER THAN ASSET-REFERENCED TOKENS OR E-MONEY TOKENS

 

1

6(11), 19(10), 51(10)

ESMA with EBA to establish standard forms, formats and templates for the purposes of making crypto- asset whitepapers available in a machine-readable format.

EC Implementing Regulation (EU) 2024/2984

Published in the Official Journal 3 December 2024. In force since 23 December 2024 and shall apply from 23 December 2025.

2

6(12), 19(11), 51(15), 66(6)

ESMA and EBA, to specify the content, methodologies and presentation of the information in respect of the sustainability indicators relating to adverse impacts on the climate and other environment-related adverse impacts

EC Delegated Regulation (EU) 2025/422

Published in the Official Journal 31 March 2025. In force since 20 April 2025 (i.e. 20th day following publication in the Official Journal).

 

 

TITLE III - ASSET REFERENCED TOKENS

 

 

CHAPTER 1- AUTHORISATION TO OFFER ASSET-REFERENCED TOKENS TO THE PUBLIC AND TO SEEK THEIR ADMISSION TO TRADING

 

3

17(8)

EBA, with ESMA and ECB, to specify the procedure for the approval of a crypto-asset whitepaper drawn up by credit institution for an asset referenced token (ART).

EC Delegated Regulation (EU) 2025/296

Published in the Official Journal 13 February 2025.

In force since 5 March 2025 (i.e. 20th day following publication in the Official Journal).

4

18(6)

EBA, in close cooperation with ESMA and the ECB, shall develop draft RTS to further specify the information to be included in the application for an authorisation.

Final report (EBA/RTS/2024/03) published (7 May 2024).

Submitted to the EC, which adopted the text on 5 June 2025. Currently subject to scrutiny by the European Parliament and the Council, following which to be published

TBC

5

18 (7)

EBA, in close cooperation with ESMA, shall develop draft ITS to establish standard forms, templates and procedures for the information to be included in the application in order to ensure uniformity across the Union.

 

Final report

(EBA/ITS/2024/03) published (7 May 2024).

 

Adopted by the EC 5

June 2025, to be published in the Official Journal.

 

TBC

 

6

22(6)

 

EBA, with ECB to specify the methodology to estimate the number and value of transactions associated to uses of ARTs, and EMTs denominated in a currency that is not an official currency of a member state, as a means of exchange within a single currency area.

 

 

Published in the Official Journal 13 February 2025.

In force since 5 March 2025 (i.e. 20th day following publication in the Official Journal).

7

22(7)

 

EBA to establish standard forms, formats and templates for the purposes of reporting referred to in Article 22(1) and the provision of the information referred to in Article 22(3) (i.e. reporting related to ARTs and EMTs denominated in a currency that is not an official currency of a member state).

 

EC Implementing Regulation (EU) 2024/2902.

 

Published in the Official Journal (28 November 2024.

In force since 18 December 2024 and applies from 1 January 2025.

 

CHAPTER 2 – OBLIGATIONS OF ISSUERS OF ASSET-REFERENCED TOKENS

 

 

8

31(5)

 

EBA, with ESMA, to specify the requirements, templates and procedures for complaint handling regarding ARTs.

 

EC Delegated Regulation (EU) 2025/293

 

Published in the Official Journal 13 February 2025.

In force since 5 March 2025 (i.e. 20th day following publication in the Official Journal).

9

32(5)

 

EBA to specify requirements for the conflicts of interest policies and procedures, and the details and methodology for the content of the disclosure of conflicts of interest for issuers of ARTs.

 

EC Delegated regulation (EU) 2025/1141

 

Published in the Official Journal 10 June 2025.

In force since 30 June 2025 (i.e. the 20th day following the publication in the Official Journal).

10

35(6)

 

EBA, with ESMA and ECB, to specify adjustment of own funds requirement and minimum features of stress testing programs of issuers of ARTs or EMTs.

 

EC Delegated Regulation (EU) 2025/415

 

Published in the Official Journal 24 March 2025.

In force since 13 April 2025 (i.e. 20th day following publication in the Official Journal).

 

 

CHAPTER 3 – RESERVE OF ASSETS

 

11

36(4)

 

EBA, in close cooperation with ESMA and the ECB, shall develop draft RTS further specifying the liquidity requirements, taking into account the size, complexity and nature of the reserve of assets and of the asset-referenced token itself.

 

Final report (EBA/RTS/2024/10) published (13 June 2024). Submitted to the EC for adoption, following which it will be subject to scrutiny by the European Parliament and the Council, and published in the Official Journal.

 

TBC

 

12

38(5)

 

EBA, in cooperation with ESMA and the ECB, shall develop draft RTS specifying the financial instruments that can be considered highly liquid and bearing minimal market risk, credit risk and concentration risk as referred to in art. 38(1).

 

Final report (EBA/RTS/2024/11) published 13 June 2024. Submitted to the EC for adoption (following which to be subject to scrutiny by the European Parliament and the Council before being published in the Official Journal).

 

TBC

 

 

 

CHAPTER 4 – ACQUISITIONS OF ISSUERS OF ASSET-REFERENCED TOKENS

 

13

42(4)

 

EBA to develop standards to establish of the detailed content of information that is necessary to carry out the assessment of proposed acquisitions of qualifying holdings in issuers of ARTs.

 

EC Delegated regulation (EU) 2025/413

 

Published in the Official Journal 31 March 2025.

In force since 20 April 2025 (i.e. 20th day following publication in the Official Journal).

 

CHAPTER 5 – SIGNIFICANT ASSET-REFERENCED TOKENS

 

14

43(11)

 

EC to adopt delegated act to further specify certain criteria for classifying ARTs and EMTs as significant.

 

EC Delegated Regulation (EU) 2024/1506

 

Published in the Official Journal 30 May 2024.

In force since 19 June 2024 (i.e. the 20th day following the publication in the Official Journal).

15

45(7)

 

EBA to develop draft RTS specifying the minimum content of the governance arrangements on the remuneration policy of issuers of significant ARTs or EMTs.

 

EC Delegated Regulation (EU) 2025/418

 

Published in Official Journal 24 March 2025.

In force since 13 April 2025 (i.e. 20th day following publication in the Official Journal).

16

45(7)

 

EBA to develop draft RTS specifying the minimum contents of the liquidity management policy and procedures as set out in paragraph 3, and liquidity requirements, including by specifying the minimum amount of deposits in each official currency referenced, which cannot be lower than 60 % of the amount referenced in each official currency.

 

Final report (EBA/RTS/2024/12) published (13 June 2024). Submitted to the EC, which adopted the text 27 June 2025.

Currently subject to scrutiny by the European Parliament and the Council, following which to be published in the Official Journal.

TBC

17

45(7)

 

EBA, in close cooperation with ESMA, shall develop draft RTS specifying the procedure and timeframe for an issuer of a significant asset-referenced token to adjust the amount of its own funds as required by paragraph 5.

 

EC Delegated regulation (EU) 2025/419

 

Published in Official Journal 24 March 2025.

In force since 13 April 2025 (i.e. 20th day following publication in the Official Journal).

 

 

TITLE V- AUTHORISATION AND OPERATING CONDITIONS FOR CRYPTO-ASSET SERVICE PROVIDERS

 

CHAPTER 1 – AUTHORISATION OF CRYPTO-ASSET SERVICE PROVIDERS

 

18

60(13)

 

ESMA, with EBA, to specify information to be included by certain financial entities in the notification of intention to provide crypto-asset services.

 

EC Delegated Regulation (EU) 2025/303

 

Published in Official Journal 20 February 2025.

In force since 12 March 2025 (i.e. 20th day following publication in the Official Journal).

19

60(14)

 

ESMA to establish standard forms, templates and procedures for the notification by certain financial entities of intention to provide crypto-asset services.

 

EC Implementing Regulation (EU) 2025/304

 

Published in Official Journal 20 February 2025.

In force since 12 March 2025 (i.e. 20th day following publication in the Official Journal).

20

62(5)

 

 

ESMA, in close cooperation with EBA, shall develop draft RTS to further specify the information to be included in the application for authorisation as a crypto-

asset service provider.

 

 

EC Delegated regulation (EU) 2025/305

 

Published in the Official Journal 31 March 2025.

 

21

62(6)

 

ESMA, in close cooperation with EBA, shall develop draft ITS to establish standard forms, templates and procedures for the information to be included in the application for authorisation as a crypto-asset service provider.

 

EC Implementing regulation (EU) 2025/306

 

Published in the Official Journal 31 March 2025.

In force since 20 April 2025 (i.e. 20th day following the publication in the Official Journal).

 

 

CHAPTER 2 – OBLIGATIONS FOR ALL CRYPTO-ASSET SERVICE PROVIDERS

 

22

68(10)(a)

 

ESMA to specify measures to ensure continuity and regulatory in the performance of crypto-asset services.

 

EC Delegated Regulation (EU) 2025/299

 

Published in the Official Journal 13 February 2025.

In force since 5 March 2025 (i.e. 20th day following publication in the Official Journal).

23

68(10)(b)

 

ESMA to develop draft RTS to further specify the records to be kept of all crypto-asset services, activities, orders and transactions undertaken.

 

EC Delegated regulation (EU) 2025/1140

 

Published in the Official Journal 10 June 2025.

In force since 30 June 2025 (i.e. the 20th day following the publication in the Official Journal).

24

71(5)

 

ESMA, with EBA, to further specify the requirements, templates and procedures for handling complaints by crypto-asst service providers.

 

EC Delegated Regulation (EU) 2025/294.

 

Published in the Official Journal 13 February 2025.

In force since 5 March 2025 (i.e. 20th day following publication in the Official Journal).

25

72(5)

 

ESMA, with EBA, to specify certain requirements in relation to conflicts of interest for crypto-asset service providers.

 

EC Delegated regulation (EU) 2025/1142

 

Published in the Official Journal 10 June 2025.

In force since 30 June 2025 (i.e. the 20th day following the publication in the Official Journal).

 

 

CHAPTER 3 – OBLIGATIONS IN RESPECT OF SPECIFIC CRYPTO-ASSET SERVICES

 

26

76(16)(a)

 

ESMA to develop draft RTS to further specify the manner in which transparency data, including the level of

disaggregation of the data to be made available to the public, is to be presented.

 

EC Delegated Regulation (EU)

2025/417

 

 

Published in Official Journal 14 March 2025.

In force since 3 April 2025. (i.e. 20th day following publication in the Official Journal).

 

27

76(16)(b)

 

ESMA to specify the content and format of order book records for crypto-asset service providers

 

EC Delegated regulation (EU) 2025/416

 

Published in Official Journal 14 March 2025.

In force since 3 April 2025. (i.e. 20th day following publication in the Official Journal).

 

 

CHAPTER 4 – ACQUISITION OF CRYPTO-ASSET SERVICE PROVIDERS

 

28

84(4)

 

ESMA to develop RTS specifying the detailed content of information necessary to carry out the assessment of a proposed acquisition of a qualifying holding in a crypto-asset service provider

 

EC Delegated regulation (EU) 2025/414.

 

Published in Official Journal 31 March 2025. In force since 20 April 2025 (i.e. 20th day following publication in the Official Journal).

 

TITLE VI - PREVENTION AND PROHIBITION OF MARKET ABUSE INVLVING CRYPTO-ASSET

 

29

88(4)

 

ESMA to specify technical means for appropriate public disclosure of inside information and for delaying public disclosure of inside information

 

EC Implementing Regulation (EU) 2024/2861

 

Published in the Official Journal 13 November 2024.

In force since 3 December 2024. (i.e. 20th day following publication in the Official Journal).

30

92(2)

 

ESMA to develop draft RTS to further specify: (a) appropriate arrangements, systems and procedures for persons to comply with paragraph 1; (b) the template to be used by persons to comply with paragraph 1; (c) for cross-border market abuse situations, coordination procedures between the relevant competent authorities for the detection and sanctioning of market abuse.

 

Final report (ESMA75-453128700-1278) published (17 December 2024). Submitted to the EC, which adopted the text 29 April 2025.

Currently subject to scrutiny by the European Parliament and the Council, following which to be published in the Official Journal.

TBC

 

 

 

TITLE VII – COMPETENT AUTHORITIES, EBA AND ESMA

 

CHAPTER 1 – POWERS OF COMPETENT AUTHORITIES AND COOPERATION BETWEEN COMPETENT AUTHORITIES, EBA AND ESMA

 

31

95(10)

 

ESMA to specify the information to be exchanged between NCAs.

 

EC Delegated regulation (EU) 2025/300

 

Published in Official Journal 31 March 2025.

In force since 20 April 2025 (i.e. 20th day following publication in the Official Journal).

 

32

95(11)

 

ESMA, with EBA, to develop standards to establish standard forms, templates and procedures for the co-operation and exchange of information between NCAs.

 

EC Implementing Regulation (EU) 2024/2545

 

Published in the Official Journal 26 November 2024.

In force since 16 December 2024 (i.e. 20th day following publication in the Official Journal).

33

96(3)

 

ESMA, with EBA, to develop standards to establish standard forms, templates and procedures for the co-operation and exchange of information between competent authorities and ESMA/EBA.

 

EC Implementing Regulation (EU) 2024/2494

 

Published in Official Journal 25 September 2024.

In force since 15 October 2024 (i.e. 20th day following publication in the Official Journal).

34

107(3)

 

ESMA to develop RTS establishing a template document for co-operation arrangements with the supervisory authorities of third countries and competent authorities.

 

EC Delegated Regulation (EU) 2025/292

 

Published in the Official Journal 13 February 2025.

In force since 5 March 2025 (i.e. 20th day

following publication in the Official Journal).

 

 

 

CHAPTER 2- ESMA REGISTER

 

35

109(8)

 

ESMA to specify data necessary for the classification of crypto-asset whitepapers and practical arrangements to ensure such data is machine-readable.

 

EC Delegated Regulation (EU) 2025/421

 

Published in Official Journal 24 March 2025.

In force since 13 April 2025 (i.e. 20th day following publication in the Official Journal).

36

110a

 

ESMA, for the purpose of ensuring the efficient collection and management of information submitted in accordance with art. 110a(1), to develop draft ITS to specify: (a) any other metadata to accompany the information; (b) the structuring of data in the information; (c) for which information a machine-readable format is required and, in such cases, which machine-readable format is to be used.

 

N/A

 

TBC

 

 

 

CHAPTER 4 – SUPERVISORY RESPONSIBILITIES OF EBA WITH RESPECT TO ISSUERS OF SIGNIFICANT ASSET-REFERENCED TOKENS AND SIGNIFICANT E-MONEY TOKENS AND COLLEGES OF SUPERVISORS

 

37

119(8)

 

EBA, with ESMA and ECB, to specify the conditions for the establishment and functioning of consultative supervisory colleges.

 

EC Delegated Regulation (EU) 2025/297

 

Published in the Official Journal 13 February 2025.

In force since 5 March 2025 (i.e. 20th day following publication in the Official Journal).

 

CHAPTER 5 – EBA’S POWERS AND COMPETENCES WITH RESPECT TO ISSUERS OF SIGNIFICANT ASSET-REFERENCED TOKENS AND ISSUERS OF SIGNIFICANT E-MONEY TOKENS

 

38

 

134(10)

 

EC to adopt delegated act specifying the procedural rules for the exercise of the power to impose fines or periodic penalty payments by the EBA on issuers of significant ARTs and EMTs.

 

EC Delegated Regulation (EU) 2024/1504

 

Published in the Official Journal 30 May 2024.

In force since 19 June 2024 (i.e. 20th day following publication in the Official Journal).

39

137(3)

 

EC to adopt a delegated act specifying the fees charged by the EBA to issuers of significant ARTs and EMTs.

 

EC Delegated Regulation (EU) 2024/1503

 

Published in the Official Journal 30 May 2024.

In force since 19 June 2024 (i.e. 20th day following publication in the Official Journal).

 

iii. GUIDELINES

#

MICA-Article

Description

Reference

Date

1.

2(5)

ESMA to issue guidelines on the conditions and criteria for the qualification of crypto-assets as financial instruments.

Final Guidelines (ESMA75453128700-1323) and translations published on the ESMA website

Published 19 March 2025. To apply 60 calendar days after publication of the translations.

2.

14(1)

ESMA, with EBA, to issue guidelines so that issuers of crypto-assets (other than asset-referenced tokens or emoney tokens) can maintain systems and security access protocols to appropriate Union standards.

Final Guidelines (ESMA75-223375936- 6132) and translations published on the ESMA website.

Published 26 February 2025. To apply 60 calendar days after publication of the translations.

3.

21(3), 63(11)

EBA and ESMA to issue guidelines on the assessment of the suitability of the members of the management body of issuers of ARTs and of the shareholders and members that have qualifying holdings in issuers of ARTs

Joint EBA and ESMA Guidelines (ESMA75- 453128700-10 / EBA/GL/2024/09) and translated into official EU languages.

Published 4 December 2024. The Guidelines apply from 4 February 2025.

4.

N/A

EBA to issue guidelines to specify templates to assist competent authorities in performing their supervisory duties regarding issuers’ compliance with own funds and liquidity requirements in Titles III and IV of MiCA, to address gaps in the data points required under Article 22 (Reporting on asset-referenced tokens) of MiCA.

Final report (EBA/GL/2024/16)

The Guidelines and translations published on the EBA website

Published 18 December 2024. To apply 2 months after publication of the translation, i.e. 26 May 2025.

5.

34 (13)

EBA, with ESMA and ECB, to issue guidelines on the minimum content of governance arrangements for issuers of ARTs.

Final report (EBA/GL/2024/06) The Guidelines have been translated into the official EU languages and published on the EBA website.

Published 5 June 2024.

Applicable since 20 December 2024.

 

45 (4)

EBA, with ESMA and the ECB, to issue guidelines with view to establishing the common reference parameters of the stress test scenarios for liquidity stress tests.

 

Final report (EBA/GL/2024/08) published (19 June

2024).

Translations published on the EBA website

30 September 2024

 

6.

45 (8)

EBA, in close cooperation with ESMA and the ECB, to issue guidelines in accordance with Article 16 of Regulation (EU) No 1093/2010 with a view to establishing the common reference parameters of the stress test scenarios to be included in the stress tests referred to in paragraph 4 of this Article.

 

Final report (EBA/GL/2024/08) published (19 June 2024).

To be translated into the official EU languages and published on the EBA website

TBC

 

7.

46 (6)

EBA, with ESMA, to specify the format of the recovery plan and the information to be provided in recovery plans of issuers of ARTs and EMTs.

 

Final report on Guidelines (EBA/GL/2024/07)

 

Published 13 June 2024.

The Guidelines apply since 13 November 2024.

8.

47 (5)

EBA to specify the content of redemption plans and the periodicity for review.

 

Final report on Guidelines (EBA/GL/2024/13).

 

Published 9 October 2024.

The Guidelines apply since 10 February 2025.

9.

61

ESMA to specify the situations in which a third-country firm is deemed to solicit clients established or situated in the Union.

 

Final guidelines (ESMA35-1872330276-2030) and translations have been published on ESMA website.

 

Published 26 February 2025.

To apply 60 calendar days from publication of translations.

10.

81 (15)

ESMA to issue guidelines on requirements relating to investor protection (i.e. suitability requirements and format of the periodic statement for portfolio management activities under MiCA).

 

Final Guidelines (ESMA35-1872330276-2031) and translations have been published on the ESMA website.

 

Published 26 March 2025.

To apply 60 calendar days from publication of translations.

11.

81 (15)

ESMA to issue guidelines specifying the criteria for the assessment of knowledge and competence.

 

Consultation Paper (ESMA35-1872330276-2004) published on 17 February 2025. ESMA will consider all comments received by 22 April 2025 and expects to publish a final report in Q3 2025.

 

TBC

 

12.

82 (2)

ESMA, with EBA, to issue guidelines for CASPs on the procedures and policies, including the rights of clients, in the context of transfer services for crypto-assets.

 

Final Guidelines (ESMA35-1872330276-2032) and translations have been published on the ESMA website.

 

Published 26 February 2025.

To apply 60 calendar days from publication of

translations.

 

13.

92 (3)

ESMA to issue guidelines on supervisory practices among the competent authorities to prevent and detect market abuse.

 

Final Guidelines and all

translations published on the ESMA website.

Published 9 July 2025.

The Guidelines apply from 9 September 2025.

14.

97 (1)

ESAs (ESMA, EBA and EIOPA) to jointly specify the content and form of the explanations and opinions accompanying crypto-asset whitepapers, and the standardised test for the classification of crypto-assets.

 

Final Guidelines (JC 2024 28) and all translations published on the ESMA website.

 

Published 10 March 2025.

The Guidelines apply from 12 May 2025.

15.

110a (6)

Where necessary, ESMA shall adopt guidelines for entities to ensure that the metadata submitted in accordance with paragraph 5, first subparagraph, point (a), are correct.

 

N/A

 

TBC

 

16.

 

EBA guidelines on templates to assist competent authorities in performing their supervisory duties regarding information requested by NCAs from issuers of ARTs and EMTs.

 

Final report on Guidelines (EBA/GL/2024/16)

Guidelines and translations published on the EBA website.

Published 18 December 2024.

To apply two months after the publication, i.e. 26 May 2025

 

D. Q&As

Questions & Answers on Regulation EU 2023/1114 (MiCA)

 

E. AUTHORISED CRYPTO-ASSETS SERVICES PROVIDERS IN GREECE (according to art. 63 of Regulation (EU) 2023/1114)

 

 

 

F. CRYPTO-ASSETS SERVICES PROVIDERS IN GREECE WITH NOTIFICATION (according to art. 60 of Regulation (EU) 2023/1114)

 

G. CRYPTOCURRENCY SERVICE PROVIDERS IN GREECE (CASPS) THROUGH PASSPORT

 

H. ΙNTERIM MiCA REGISTERS

ΙNTERIM MiCA REGISTERS