The Zumo team is committed to providing Europe’s crypto-asset service providers (CASPs) with both the knowledge and the resources they need to confidently comply with the Markets in Crypto-Assets (MiCA) regulation, and then thrive in the MiCA environment.

We’re particularly focused on MiCA’s mandated sustainability disclosures, with our recent research revealing a worrying sustainability compliance knowledge gap. Zumo’s MiCA CASP Sustainability Readiness Assessment report showed that while 75% of respondents are ‘very familiar’ with the MiCA regulation, less than a third say they are ‘knowledgeable’ about its sustainability disclosure requirements.

As Peter Kerstens of the European Commission commented in our report, taking action on this topic is part of how the industry does better and also plays into a larger strategic imperative: “I believe that ultimately the market will respond to this and will put those crypto assets that have better sustainability records ahead…CASPs should recognise this. They should not look at MiCA – be it the sustainability or other requirements – from a compliance perspective only. They should also and preferably look at it as an opportunity to access the EU-wide market.”

In an effort to close the gap, and help to build trust in the nascent digital assets sector, we’re taking an active role in the MICAR Expert Roundtable Series. Initiated by Mariana de la Roche and Dr. Nina-Luisa Siedler, the timely Series seeks to build greater legal clarity within the European Union’s (EU’s) evolving regulatory framework for crypto-assets under MiCA. 

The latest session was hosted at Crucible Hub in the Norwegian capital Oslo, bringing together regulators, policymakers, and industry experts to engage in high-level discussions on MiCA’s implementation in the European Economic Area (EEA), its interaction with existing financial regulations, and the broader impact on operational resilience and compliance strategies. 

The session kicked off with an important discussion about MiCA’s interplay with other financial regulations, notably the Payment Services Directive 2 (PSD2), an EU law that regulates payments. Participants raised the need to develop a standardised regulatory taxonomy, saying the industry should lead on the creation of a taxonomy that clearly outlines which activities fall under MiCA, PSD2, or both, therefore providing practical compliance guidelines for CASPs. This served to highlight the broader need for harmonisation across EU Member States, with a call for National Competent Authorities (NCAs) to align their supervisory practices to ensure CASPs aren’t subjected to conflicting interpretations of MiCA and PSD2.

The day’s final topic, presented by Zumo’s Sustainability Director Kirsteen Harrison, then delved into the challenges that CASPs are facing in addressing MiCA’s sustainability disclosure requirements, as detailed in MiCA Article 66.

The problems associated with playing on an uneven field

The discussion highlighted regulatory uncertainty, grandfathering disparities, and the absence of clear implementation guidelines, all of which are combining to contribute to an uneven playing field across EU jurisdictions. 

One major concern is that CASPs in jurisdictions with shorter grandfathering periods must comply with MiCA’s sustainability requirements sooner than their counterparts in other Member States, creating a first-mover disadvantage. This is a real problem, given that Zumo’s survey revealed the majority of CASPs are keen to move proactively – most within six months. 

Early adopters in jurisdictions with shorter grandfathering periods – and Norway’s is yet to be announced – must now therefore determine disclosure methodologies and data sources, and then navigate compliance without the benefit of regulatory clarifications, enforcement precedents, or additional guidance, while later entrants can observe and adapt based on evolving interpretations. The European Securities and Markets Authority (ESMA) has not specifically indicated that it plans to issue further guidance, leaving CASPs without a clear regulatory reference point.

Additionally, there is a misalignment between CASP and crypto-asset issuer reporting obligations. While CASPs must immediately comply with sustainability disclosure requirements, issuers of the assets they service are able to benefit from a white paper grace period (encompassing asset-level sustainability data) for existing trading platform listings. This gap further complicates CASP compliance efforts, as they may lack access to critical sustainability data. 

Some participants from Norway voiced frustration that they had not been part of the original EU legislative discussions on MiCA, yet now find themselves subject to these requirements as part of the broader regulatory framework. This sentiment reflects wider concerns about the imposition of EU financial regulations on non-EU jurisdictions within the EEA, raising questions about the extent to which local regulatory autonomy can be maintained.

A pressing need for collaborative solutions 

The discussion then moved on to industry-driven solutions to support CASPs in demonstrating compliance both efficiently and consistently across EU markets. Half of those surveyed for Zumo’s MiCA CASP Sustainability Readiness Assessment report felt a lack of ready-made technological solutions are a blocker in their efforts to achieve MiCA sustainability compliance. How can we change this picture? 

It was noted that MiCA requires CASPs to disclose sustainability-related information under Article 66, but the lack of detailed operational guidance complicates compliance. Furthermore, Member States have taken different approaches to implementation, creating inconsistencies that will place some market participants at a disadvantage.

To address these challenges, participants proposed developing an industry-driven compliance preparedness initiative, modelled on existing proposals for a Wiki-style MiCA resource. A centralised compliance toolkit would help CASPs navigate sustainability disclosures by providing structured guidance, practical templates, and best practices. Additionally, a collaborative platform for knowledge-sharing could serve to enhance industry alignment by allowing CASPs to exchange experiences, regulatory updates, and lessons learned from early implementation efforts.

Finally, ongoing engagement with ESMA and the European Commission will help to ensure that industry concerns are considered in future refinements of the regulatory framework. By taking a more proactive approach to compliance preparedness, the industry can create a more transparent, standardised, and effective sustainability disclosure process under MiCA.

It was a fascinating discussion, and we would like to again extend our thanks to those who took part. In summary, the primary recommendations that emerged from Zumo’s session are:

• The development of an industry-wide compliance preparedness toolkit to provide the continent’s CASPs with more structured guidance on sustainability disclosures.
• The establishment of a collaborative knowledge-sharing initiative, enabling CASPs to exchange best practices and regulatory updates in real time.
• The encouragement of standardisation efforts to help mitigate the risk of regulatory fragmentation and ensure MiCA’s sustainability disclosures are applied consistently across Member States.

By fostering dialogue, championing actionable steps, and providing new, accessible solutions – such as  our Oxygen product – we’re working hard to support the transition towards a more transparent, sustainable, and compliant crypto industry. We will be travelling extensively across Europe in the coming weeks to take part in more sessions of the MICAR Expert Roundtable Series – so watch this space!

The full report of the Oslo session is available to download at: Dublin MiCAR Roundtable E… | BlackVogel