The Hyperliquid Policy Committee filed its first formal submission outside the United States on October 1, 2026, urging the European Commission to bring on-chain perpetual contracts under MiFID II rather than draft new crypto-specific legislation.

The filing responds to a Commission consultation on how the Markets in Crypto-Assets (MiCA) framework should evolve. The committee's core argument is procedural thrift: Europe already has a functioning rulebook for financial instruments and trading venues, and Brussels should stretch it rather than start a fresh legislative process.

What does the committee actually want?

The centerpiece concerns on-chain perps — derivatives that let traders take price exposure without an expiry date. The HPC wants them bolted onto MiFID II, the EU's existing regime for financial instruments, and it asks the European Securities and Markets Authority (ESMA) to issue guidance on how that regime should apply to these products.

Two principles anchor the argument: technology neutrality and economic substance. Regulators, the committee argues, should judge a product by what it does, not by whether it runs on a blockchain or a bank server.

That framing serves a concrete objective. Europe already restricts retail access to contracts for difference — leveraged products where a trader bets on price moves against a market maker. The HPC says on-chain perps differ structurally: they run on a public central limit order book, matching buyers and sellers openly rather than pairing retail traders against a dealer. Because of that gap, CFD-style retail curbs should not automatically carry over to on-chain perps.

Where does the reporting burden come in?

The filing also targets paperwork. The committee pushes to cut duplicate reporting obligations for data that already lives on public blockchains.

The logic is straightforward. Public chains are open and verifiable by design, so requiring firms to separately report information anyone can inspect looks redundant. For venues operating transparent order books, the filing implies, the chain itself can serve as the record.

Why is the timing significant?

The submission lands a few months after a key MiCA milestone. The framework's transitional period ended on July 1, 2026, raising the possibility of regulatory gaps for on-chain derivatives. MiCA was built largely around crypto assets and service providers, and products like perps sit awkwardly between crypto rules and traditional securities law.

The HPC's proposal offers a way to close that gap without waiting years for new legislation. MiFID II already exists, already has supervisors, and already covers derivatives. The committee is asking Brussels to extend its reach rather than rebuild from scratch.

Who is behind the filing?

The Hyperliquid Policy Committee was set up in February 2026 and is funded by the Hyperliquid Foundation, serving as the policy arm of the Hyperliquid ecosystem, which centers on decentralized trading. Until now, its advocacy had focused on the United States; the European Commission submission marks its first policy intervention abroad.

The funding structure warrants scrutiny. A policy body backed by a trading ecosystem's foundation is, predictably, arguing for rules that would make on-chain trading easier to offer in Europe — including looser retail-access treatment than CFDs receive.

For the Commission, the decision point is now structural: fold a fast-growing derivatives category into a legacy framework via ESMA guidance, or open a multi-year legislative track. How Brussels answers the MiCA consultation will shape whether on-chain perps get a supervised path into the EU market — and on whose terms.