The Markets in Crypto-Assets Regulation (MiCA) is the most comprehensive piece of crypto law adopted by the European Union (EU) to date. It officially came into force in 2023, and by 2024, key provisions started to apply across EU member states. While MiCA marked a turning point for crypto regulation, it was built around the technologies and services dominant in 2019–2020.
However, the industry continues to evolve at an accelerated pace, and so evolves every crypto law service, compliance service, advisory service, and regulatory service, aiming to remain relevant in the shifting digital asset landscape. As the crypto market evolves, so do the standards for law enforcement and service delivery, especially in jurisdictions across the EU.
Now that MiCA is in full effect, a central question emerges: how will this law evolve in the coming years to address innovation in decentralized finance (DeFi), DAOs, tokenized real-world assets (RWAs), and AI-based financial instruments? Ongoing EU regulatory reviews and updates suggest that MiCA will continue to evolve in phases, ensuring its relevance as both technology and crypto services transform. Future iterations of MiCA may include expanded definitions and new mechanisms, allowing the EU to better govern the evolving digital economy through responsive law and service frameworks.
Current MiCA limits and how they may evolve
MiCA was developed to bring legal clarity to centralized crypto service providers, such as exchanges, custodians, and stablecoin issuers. But many parts of the crypto industry still fall outside its current scope.
Decentralized lending platforms, AMMs, and aggregators often operate without a central entity and aren’t regulated under existing law.
Governance tokens and DAO structures based on smart contracts continue to challenge the foundational legal assumptions on which MiCA was built.
MiCA’s definition of crypto-assets excludes NFTs, but the line begins to blur with fractionalized NFTs or extensive collections that function as financial instruments.
Platforms that leverage AI for trading, risk scoring, or investment advice raise new compliance issues that remain unaddressed by today’s crypto law framework.
These regulatory gaps highlight why this crypto law must evolve further to remain effective as both technology and market dynamics rapidly shift. Continuing to grow is the only way the law can keep up with innovation. Crypto founders need flexible legal tools and service models to adapt quickly as the law evolves in this dynamic environment.
Signals from EU regulators and how the situation will evolve further under MiCa
In 2024, both ESMA and the EBA issued technical guidance and discussion papers pointing out several areas where MiCA may need to evolve.
One key area of focus is DeFi. While MiCA currently evolves centralized actors, regulators are increasingly aware that decentralized crypto services can pose similar risks, especially at scale.
There’s now a shift toward a functionality-based approach to regulation:
“Decentralized” platforms with admin keys or upgradeable contracts may still fall within regulatory oversight.
Frontend interfaces, developers, or infrastructure providers may be classified as enablers of regulated crypto services.
New categories of law may emerge, including decentralized service facilitators, non-custodial crypto service providers, and others.
This evolving law and adaptive regulation would enable legal frameworks to align with the crypto space, ensuring that innovation and compliance develop in tandem. To support this shift, crypto service providers must be prepared for regulatory changes that impact how their products are classified under evolving laws.
Tokenisation, tangible assets (RWA), MiCA, and how they will evolve
As tokenization of real-world assets grows, more crypto services are emerging that intersect with traditional finance. Tokenized real estate, shares, and bonds are increasingly traded via blockchain.
Currently, tokenized securities fall under MiFID II, not MiCA. However, as financial institutions explore blockchain settlements, a regulatory overlap is becoming unavoidable.
Future evolution of MiCA may involve:
Unified classification schemes between crypto and traditional finance under MiCA
Enhanced disclosure rules for collateral backing tokenized instruments under MiCA
Lessons from the DLT Pilot Regime, which may inform how crypto law services support tokenized markets under MiCA
Evolving requires robust law service strategies that align with both traditional and crypto-specific frameworks.
Evolution of AI and the future of cryptocurrency regulation under MiCa
Artificial intelligence is merging with cryptocurrency in areas such as automated trading, fraud detection, and portfolio management. However, MiCA barely mentions AI, a gap that will likely need to be addressed.
Key future issues in AI, law, and MiCA:
AI-driven investment decisions may require explainability and audit trails to meet regulatory scrutiny and MiCA requirements.
Autonomous agents raise accountability concerns. If an AI agent breaches rules, who’s liable?
Future versions of MiCA may integrate AI-related governance requirements aligned with GDPR and other crypto law services.
As both AI and crypto services evolve, so must the rules governing them. We’re entering a phase where legal frameworks, business models, and regulatory expectations must co-evolve rapidly.
What does it mean for founders and investors?
While MiCA provides legal clarity and establishes an EU-wide licensing regime for crypto services, it should be seen as a foundation, not the final destination. Innovators building in DeFi, RWAs, or AI must be prepared for additional layers of law and regulation that will continue to emerge.
Strategic recommendations:
Utilize legal and operational structures that are designed to evolve as crypto law adapts and new frameworks emerge.
Actively monitor regulatory updates and participate in public consultations to stay aligned with evolving law.
Evolve systems with transparency, resilience, and long-term compliance in mind to meet future law requirements.
MiCA is a regulatory landmark, but certainly not the endgame. As DeFi, tokenization, and AI redefine the scope of crypto services, crypto law must evolve accordingly. The success of the industry will depend on forward-thinking, flexible law that enables innovation while safeguarding market integrity. Only a holistic approach to crypto law services can support such evolution.
How can Manimama Law Firm assist with your crypto project and help it evolve?
At Manimama Law Firm, we help projects stay compliant while embracing innovation. Whether you’re navigating MiCA compliance, preparing for the following MiCA amendments, launching AI-integrated crypto services, or tokenizing real-world assets, our team provides legal expertise and strategic service offerings that evolve with the market and are ready to adapt further.
Our team delivers tailored legal services, compliance services, advisory services, and risk management services that go beyond simple compliance, helping you structure your project for longevity and success in a rapidly evolving industry where MiCA regulations and legal frameworks are constantly changing. Our crypto law service models are designed to grow in tandem with your business and adapt as MiCA-based law requirements evolve across the EU.
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