As Europe's digital asset ecosystem matures, the review of the EU Markets in Crypto Assets Regulation (MiCA) presents an opportunity to address the conditions needed for tokenisation to scale across the European financial system. For Euronext, the objective is clear: ensure that innovation can develop within a framework that remains technology-neutral, legally certain, and fully integrated with existing capital market infrastructures. Achieving this ambition requires action in various key areas:
1. Preserve a technology-neutral classification framework
Euronext supports preserving the current approach enshrined in the EU framework based on the principle of technological neutrality, whereby the regulatory treatment of an asset does not depend on the underlying technology. In this vein, crypto-assets that qualify as financial instruments by virtue of their fundamental economic characteristics and functions should continue to be regulated under MiFID and under relevant sectoral legislation, as opposed to MiCA. ESMA's existing Guidelines for the classification of crypto-assets are welcome, but further improvements could be considered to ensure consistent application across EU Member States.
2. Recognise the role of DLT-based cash in securities settlement
To support tokenised financial markets in Europe, it is important to recognise the role that regulated stablecoins and tokenised deposits can play as enablers of DLT-based settlement. Euronext considers central bank money, including wholesale CBDC, as the safest and preferred settlement asset. At the same time, market-driven solutions, including MiCA-regulated electronic money tokens (EMTs) and tokenised deposits, can play an important complementary role alongside CBDC, especially as market interest grows for DLT-based solutions for cash leg settlement. To realise these benefits, the regulatory framework should remain technology-neutral and allow regulated stablecoins and tokenised deposits to develop in parallel with wholesale CBDCs and to be integrated within the EU post-trade infrastructure.
3. Ensure legal certainty for tokenised assets
Greater EU-level harmonisation regarding the legal treatment of tokens will be essential to enable the emergence of an integrated ecosystem across Europe. Today, significant differences and gaps remain across national frameworks. The resulting legal complexity and uncertainty are major barriers for tokenisation to scale at pan-European level. The MiCA review should therefore be used as an opportunity to advance legal harmonisation across the tokens’ lifecycle, particularly in areas including DLT-based issuance, recognition of DLT-based transfers and settlements, enforceability of collateral arrangements, client asset protection, and settlement finality.
By addressing these priorities, Europe can create the conditions for tokenisation to evolve from fragmented initiatives into a truly integrated European market, enabling European capital markets to fully leverage the benefits of DLT innovation.
Download Euronext’s response to the European Commission’s targeted consultation on the MiCA review.