MiCA's Passport Works, But EU Crypto Users Still Hit Payment Borders

Hungary's extra crypto validation requirement — the rule that forced Revolut to tell Hungarian customers to sell their crypto by Dec. 18, 2025 — is gone, but the European Union's single crypto market still doesn't feel single to customers. The MiCA passport gives licensed firms EU-wide reach under Article 59(7), yet funding methods, corporate structures and outdated support pages keep borders alive inside the bloc.

The European Commission opened an infringement procedure against Hungary on Jan. 30, arguing that MiCA gave the country no basis for its added authorization regime, which carried criminal penalties and was introduced through 2025 amendments. The Commission acknowledged Hungary's anti-money-laundering concerns but insisted any measures comply with EU law. Hungary repealed the requirement before any court ruling: Act XXXVIII of 2026 took effect on Aug. 7, and its explanatory memorandum conceded the requirement was incompatible with EU crypto regulation.

What did the repeal actually change?

In practice, room to reopen — not automatic service. Bitvavo announced it would return to Hungary, but its general eligibility page, updated Nov. 4, still omits Hungary from the list of supported countries, while its dedicated reopening notice and country payment page list services for Hungarian customers. A prospective user reading two pages from the same exchange could reach different conclusions.

Revolut's case shows how support pages can outlive the restrictions they describe. The company's crypto subsidiary received MiCA authorization in Cyprus in October 2025, and France's financial regulator lists it as authorized there under the same framework. Its Hungarian shutdown notice remains live even though the underlying law is repealed. Under Article 66, firms must describe their services accurately and without misleading customers; a regulator assessing Revolut's notice would need to establish what the company currently offers in Hungary and why any restriction remains.

Where do customers still see borders?

Mostly at the payment menu. Coinbase's European payment guide lists Easy Bank Transfer for cash deposits in the Netherlands, Finland, France, Germany and Ireland, card deposits in the Netherlands, Italy and Spain, and BLIK for Polish customers buying crypto directly. Kraken's documentation lets Dutch residents deposit euros via iDEAL but requires a different method for withdrawals. Under Article 70(4), an exchange can handle associated payment services itself or through a partner, provided the payment handler holds the required authorization and customers are told who provides the service and on what terms.

These differences don't automatically breach MiCA. Article 76 requires trading platforms to apply objective, non-discriminatory access rules, and Article 77 obliges firms dealing on own account to publish a non-discriminatory policy on whom they serve. ESMA guidance says a provider must fill an order once the customer meets the published conditions. Proving a breach means comparing customers requesting the same regulated service from the same legal entity. Separately, refusing an eligible EU bank account purely because of its IBAN can amount to IBAN discrimination under SEPA rules — but that requires evidence of an actual refusal, which public payment guides don't provide.

Why does one app hide several rulebooks?

Because the licenses sit with different companies. Kraken's EEA terms, effective Oct. 14, put core crypto services under an Irish MiCA-authorized entity, electronic money under another Irish company, and derivatives and xStocks under a Cypriot investment firm, with separate terms for staking and margin trading. Coinbase's migration notice shows the same split: Coinbase Luxembourg took over crypto services under its MiCA authorization while Coinbase Ireland kept electronic money services. One balance, two responsible firms.

Staking exposes a further gap. MiCA has no dedicated staking regime, but custody of a customer's crypto or private keys while staking on their behalf falls under MiCA's authorization and custody requirements, per Commission guidance published through ESMA. ESMA has also warned that customers may wrongly assume unlicensed products offered alongside regulated services carry the same protections.

MiCA's maximum transitional period ended on July 1, 2026, so every EU crypto provider now operates fully under the regulation — and the next test of the single market will come from enforcement actions and infringement procedures, not new legislation.