What MiCAR means for your Bitcoin

A plain explanation of the European Union's crypto-asset regulation, and how it affects people who hold Bitcoin in Europe.

The European Union now has a single regulatory framework for Bitcoin and other crypto-assets. It is called MiCAR, the Markets in Crypto-Assets Regulation (Regulation (EU) 2023/1114). For anyone active in crypto-asset markets in Europe, whether they hold Bitcoin themselves or use a crypto-asset service provider (CASP), this regulation sets, among other things, what those providers must do with client assets, how they handle client money, and what happens if it fails. MiCAR also governs much more than crypto-asset service providers, including how crypto-assets are issued and traded and other aspects of the European crypto-assets market.

This article explains what MiCAR is, what it requires, and what it means specifically for Bitcoin holders. It is written for people who want to understand the framework rather than the headlines.

What is MiCAR?

MiCAR is the EU's binding regulatory framework for the issuance, offering and trading of crypto-assets and also applies to crypto-asset service providers (CASPs). The regulation sorts crypto-assets into three groups: asset-referenced tokens, e-money tokens, and all other crypto-assets. Bitcoin falls into the third group. MiCAR also regulates the companies that handle these assets for clients, known as crypto-asset service providers, or CASPs.  A number of services fall under MiCAR, including custody, brokerage, portfolio management and transfers of crypto-assets, among others.

Before MiCAR, each Member State had its own approach to regulating crypto-assets, and some had none at all. A Bitcoin holder in the Netherlands and one in Spain could face different protections depending on where their crypto-asset service provider was registered. MiCAR replaces that patchwork with a single, EU-wide framework.

Under MiCAR, national regulators, such as the Dutch Authority for the Financial Markets (AFM), supervise CASPs operating in their own jurisdiction.

The MiCAR timeline

MiCAR has been applied in phases, so existing crypto-asset service providers and parties throughout the market have had time to adapt without cutting off client access.

The transitional period allowed CASPs that were already active before 30 December 2024 to continue operating while they applied for authorisation. Member States set their own length for this period, up to the EU-wide cut-off of 1 July 2026. The Netherlands chose a shorter, six-month transitional period, which ended on 30 June 2025. From 1 July 2026, any entity providing crypto-asset services in the EU without a MiCAR licence is in breach of EU law.

What MiCAR asks of CASPs offering Bitcoin services

Among other things, MiCAR sets out requirements that apply to a crypto-asset service provider (CASP) holding Bitcoin on behalf of clients. The table below summarises the main ones.

Own funds

Authorised CASPs must hold a minimum own funds, calculated from their fixed overheads or a fixed floor, depending on the services they offer. These funds act as a buffer against operational losses.

Segregation of client Bitcoin

A provider of crypto-asset services must keep client Bitcoin and client funds separate from its own assets. In cases of insolvency, client assets are not part of the CASPs estate and are not available to its creditors.

AML, KYC, and the Transfer of Funds Regulation

Authorised CASPs must perform know-your-customer and anti-money-laundering due diligence. The Transfer of Funds Regulation, which applies from 30 December 2024, requires providers of crypto-asset services to collect and pass on sender and recipient information for transfers. This is the same standard that is applied similarly to bank wire transfers.

Operational resilience and cybersecurity

CASPs are required to comply with the Digital Operational Resilience Act (DORA) which requires documented security policies, incident response procedures and business continuity plans. CASPs must report significant operational incidents to their regulator within set timeframes.

What segregation does and does not mean

Segregation is often described as protection for client assets,  and it is important to be precise about what it covers. Segregation protects client crypto from a CASPs creditors if the CASP becomes insolvent. It separates what belongs to clients from what belongs to the company.

Segregation does not mean a provider of crypto-asset services can never restrict access to an account. Authorised CASPs operate under anti-money-laundering law, counter-terrorist financing law and sanctions law. These rules require a CASP to be able to freeze or block an account, and to restrict access to the crypto held in it, when the law requires it. A crypto-asset service provider that does not do this could itself be in breach of its obligations.

Where Blockrise stands

Blockrise Capital B.V. holds a MiCAR licence, number 41000029, issued by the Dutch Authority for the Financial Markets (AFM). It is supervised by the AFM and De Nederlandsche Bank (DNB), and it provides regulated services for Bitcoin, including custody and administration of crypto-assets, execution of orders on behalf of clients, portfolio management, and transfer services for crypto-assets.

Blockrise Lending B.V. is a group company of Blockrise Capital B.V. It does not hold a MiCAR licence, and offers Bitcoin-backed loans, which are not a MiCAR-regulated product.

What this means if you hold Bitcoin in Europe

MiCAR sets a baseline that crypto-asset service providers must adhere to, covering the requirements set out above. MiCAR also requires regulated entities to publish clear information about the assets they offer, to handle complaints through a formal process, and to inform clients about material changes to their terms.

MiCAR reduces the risk that comes from how a CASP is run. It does not change the nature of Bitcoin itself. The price of Bitcoin can move sharply, and the value of a holding can fall as well as rise. The framework addresses the conduct of crypto-asset service providers and operational risks. It does not remove market risk.

Frequently asked questions

What does MiCAR mean for Bitcoin I hold with a CASP?

MiCAR introduces safeguards surrounding the provision of crypto asset services in Europe. While it does not remove the risks entirely, having a unified framework which introduces obligations on CASPs reduces the risk that crypto asset services are offered irresponsibly or in a way that is not transparent

What happens if I use an unauthorised CASP after 1 July 2026?

From 1 July 2026, European CASPs serving EU clients without a MiCAR licence are in breach of EU law.  Holdings with such a provider are not covered by MiCAR's protections concerning segregation, own funds, and complaint handling.

Is Blockrise authorised, and which regulator issued the licence?

Blockrise Capital B.V. holds a MiCAR licence, number 41000029, issued by the AFM. Blockrise Lending B.V. does not hold a MiCAR licence, and Bitcoin-backed loans are not a MiCAR-regulated product.

What is MiCAR passporting?

Passporting lets a authorised CASP in one EEA country offer services in other EEA countries under the same framework, without a separate licence in each one.

Does a MiCAR licence remove all risk?

No. A licence means a CASP has been authorised by their national competent authority to provide crypto asset services in a set number of EU countries. Crypto remains volatile, and the value of a holding can fall as well as rise. MiCAR aims to mitigate provider and operational risk. It does not remove market risk.

Investing in crypto involves risks and may result in partial or complete loss. Only invest if you understand crypto and with money you can afford to lose.

About Blockrise:

Blockrise is a Bitcoin only platform based in Rotterdam, the Netherlands. Founded in 2017. We offer custody, wealth management, brokerage, Bitcoin backed loans, treasury services, secured lending, and estate planning, all focused exclusively on Bitcoin. Blockrise Capital B.V. holds a MiCAR licence (number 41000029) issued by the Dutch Authority for the Financial Markets (AFM).

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