The European Commission's public consultation on the Markets in Crypto-Assets Regulation (MiCA) has been collecting feedback from industry participants, national regulators and the public since May 20, 2026, with the deadline recently extended to September 30. The review marks the first formal assessment of the EU's flagship crypto framework, and the early data points to structural friction between market access and compliance costs.

The numbers as of September 1, 2026 describe an uneven rollout. Firms have issued 39 e-money tokens under MiCA. The number of authorized asset-referenced tokens — the category covering stablecoins backed by baskets of assets or commodities — stands at zero. That zero is the clearest signal yet that at least one corner of the framework is not functioning as its drafters intended.

MiCA took effect in phases. Stablecoin-specific rules went live on June 30, 2024, and broader requirements for crypto-asset service providers (CASPs) followed on December 30, 2024. The framework was designed to give the EU a first-mover advantage, establishing a single licensing regime that lets firms passport their services across all 27 member states.

The cost structure underpinning that regime is tiered. Capital requirements range from €50,000 for firms offering basic Class 1 services to €150,000 for Class 3 operators such as trading platforms. Ongoing compliance costs are projected to run from tens to hundreds of thousands of euros annually per firm, and larger operations face bills that could reach into the millions.

For smaller CASPs, those figures translate into a strategic calculation. A firm weighing authorization must now budget for capital floors, supervisory reporting and legal review before it can passport a single service across the bloc. The compliance burden is effectively a fixed cost, and it weighs most heavily on the smallest operators — a dynamic that pushes the market toward consolidation among well-capitalized players.

The European Banking Authority (EBA) entered the debate on September 24, 2026, recommending that the Commission strengthen regulations around multi-issuer stablecoins and clarify existing definitions within the framework. Multi-issuer stablecoins — arrangements where multiple entities share responsibility for maintaining a token's peg — present supervisory challenges the current text does not fully resolve, according to the authority's assessment.

The EBA's intervention matters because it comes from the body directly responsible for drafting the technical standards that asset-referenced and e-money token issuers must follow. A call for definitional clarity from that institution signals that the ambiguity is not merely an industry complaint but a supervisory concern.

What happens next is procedurally defined. The feedback collected through September 30 will feed into reports the Commission must prepare by June 2027. Those reports could lead to legislative amendments, meaning the MiCA framework that firms are currently spending millions to comply with might look meaningfully different within a year or two. Compliance investments made today carry regulatory-design risk that extends beyond ordinary implementation costs.

The passporting mechanism remains MiCA's strongest selling point. A single license granting access to a market of roughly 450 million consumers is a competitive advantage no other jurisdiction currently replicates at the same scale. The question the consultation data raises is whether that advantage justifies the cost of admission, particularly for token categories — asset-referenced instruments among them — where no issuer has yet crossed the threshold.

The zero count on authorized asset-referenced tokens also carries market-structure implications. Issuers of basket-backed stablecoins have effectively ceded the EU market to e-money token issuers, concentrating euro-denominated stablecoin activity in the bank-friendly e-money category. If the June 2027 reports do not adjust the requirements for asset-referenced tokens, that concentration is likely to harden.

The Commission now faces a narrow policy window. Feedback submitted by September 30 shapes the scope of the June 2027 reports, and those reports determine whether the next iteration of MiCA eases compliance friction or doubles down on the current approach. Firms operating in the EU should treat the coming nine months as the effective window to influence the framework's design before potential amendments lock in.