The European Union's Markets in Crypto-Assets Regulation (MiCA) established a framework allowing authorized crypto companies to operate across member states without obtaining individual licenses in each country. However, the regulation has not eliminated market fragmentation, with customers encountering different access rules, payment methods, and service providers depending on their location and the exchange they use.
Hungary's experience illustrates the challenges. In 2025, Hungary added extra authorization requirements for crypto conversions, effectively creating an additional layer of regulation beyond MiCA. This prompted several exchanges, including Revolut, to halt crypto services for Hungarian customers. On January 30, the European Commission opened an infringement procedure, arguing that Hungary's requirements conflicted with MiCA. Hungary repealed the requirement before a court ruling, with Act XXXVIII of 2026 taking effect on August 7.
Once Hungary removed the restriction, exchanges like Bitvavo announced the return of trading and euro deposits for Hungarian customers, with new registrations reopening on September 7. Yet some exchanges, including Revolut, maintained outdated notices describing service shutdowns and account closures, creating confusion about which services remained unavailable.
The Passport System and Its Limits
Under MiCA's Article 59(7), authorized companies can offer approved services across the EU without opening local offices. They must notify their home regulator of their intended markets and services. Article 65 allows them to begin operations once confirmation is received or no later than 15 days after submission.
Despite this framework, customers encounter different payment methods across borders. Coinbase's payment guide lists Easy Bank Transfer for deposits in the Netherlands, Finland, France, Germany, and Ireland, while card deposits are available only in the Netherlands, Italy, and Spain. Polish customers can use BLIK to purchase crypto directly. Kraken's documentation shows Dutch residents can use iDEAL for euro deposits, with different withdrawal methods required.
Under MiCA Article 70(4), exchanges can handle payment services themselves or through partners, provided the payment handler holds required authorization. The regulation requires exchanges to disclose which company provides payment services and on what terms.
Regulatory Requirements and Transparency Gaps
MiCA imposes obligations on how companies provide access to crypto services. Article 76 requires trading platforms to apply objective, non-discriminatory access rules and transparent, fair, non-discriminatory fees. Article 77 applies when providers buy or sell crypto directly with customers, requiring them to publish non-discriminatory policies explaining whom they serve and what conditions customers must meet.
The European Securities and Markets Authority (ESMA) has clarified that providers must execute orders once customers meet published conditions. However, public payment guides often provide incomplete information. They show which local payment methods each exchange supports but not whether providers reject eligible customers based solely on their location.
Multiple Companies Within One App
A single app can involve different licensed companies handling different services. Kraken's European terms assign core crypto services to an Irish MiCA-authorized entity, while another Irish company handles electronic money and a Cypriot firm provides derivatives and xStocks. Coinbase similarly assigned crypto services to Coinbase Luxembourg under MiCA authorization, while Coinbase Ireland continues providing electronic money services.
Staking illustrates how protections depend on what providers do with customer assets. MiCA has no separate staking regime, but if a provider holds crypto or private keys while staking on a customer's behalf, that custody activity requires MiCA authorization and compliance with custody requirements.
Under Article 66, companies must explain their services accurately and clearly without misleading customers. The fragmented information provided by exchanges—sometimes showing different country lists on different pages or maintaining outdated service notices—can leave customers uncertain about their eligibility and available services.
