MiCA Gave Crypto Firms an EU Passport. Customers Still Run Into Borders.

Hungary lifted an additional layer of crypto restrictions in August. For customers who had spent months waiting to trade normally again, that should have settled the matter.

What they were actually told still varied by app.

Bitvavo said trading and euro deposits were returning for Hungarian customers, with new registrations reopening on Sept. 7. As of Nov. 13, Revolut’s Hungarian help page still described the suspension of its crypto services and account closures tied to a December 2025 deadline.

Support pages often outlast the rules they describe, so these notices reflect what each company published rather than what a customer would actually be able to do — confirming live access would require testing an account or a transaction.

The European Union spent years building a shared framework intended to let authorized crypto companies expand without securing a separate license in every member state.

In practice, customers can still encounter different funding routes across borders, or find that the crypto and cash balances sitting in the same app are held by different companies operating under different rules. The EU’s Markets in Crypto-Assets Regulation (MiCA) permits some of those variations and caps others.

MiCA cleared away Hungary’s extra layer of permission

MiCA grants authorized crypto companies a passport. Under Article 59(7), a firm can offer its approved services elsewhere in the EU without establishing a local office. It simply notifies its home regulator of where it intends to operate and which services it plans to provide.

Under Article 65, the firm can begin once it receives confirmation that the notification has reached the relevant authorities, and in any event no later than 15 days after filing it.

Revolut’s crypto subsidiary obtained MiCA authorization in Cyprus in October 2025, and France’s financial regulator lists it as permitted to offer crypto services in France under the same framework. The passport allows providers to enter new markets and to choose which approved services they make available where.

Hungary disrupted that arrangement in 2025, when amendments to its crypto legislation introduced an additional requirement to validate crypto conversions, enforced through criminal penalties.

Firms already authorized under MiCA were suddenly subject to a further Hungarian condition. Revolut instructed customers to sell their crypto by Dec. 18, 2025, stating that it would liquidate any remaining holdings automatically and close their crypto accounts.

On Jan. 30, the European Commission launched an infringement procedure, taking the position that MiCA provided Hungary with no legal basis for an additional authorization regime.

The Commission accepted Hungary’s interest in combating money laundering but maintained that any measures it adopted had to conform to EU law. Hungary repealed the requirement before a court could rule.

Act XXXVIII of 2026 entered into force on Aug. 7, and its official explanatory memorandum conceded that the requirement was incompatible with EU crypto regulation. MiCA’s maximum transitional period had already expired on July 1, 2026.

The repeal created room for companies to restore services, as Bitvavo did. Even so, the exchange’s general eligibility page, last updated Nov. 4, left Hungary off its list of supported countries. Its dedicated reopening notice and its country payments page both described services for Hungarian customers.

The dedicated notice more accurately reflects what Bitvavo said it would offer in Hungary, yet a prospective customer reading two pages from the same exchange could still come away with conflicting answers about whether they qualify.

The boundary has shifted from the statute book to the payment screen

Once an account exists, national differences tend to surface at the point of adding funds.

Coinbase’s European payment guide lists Easy Bank Transfer for cash deposits in the Netherlands, Finland, France, Germany, and Ireland. Card deposits appear for the Netherlands, Italy, and Spain, while Polish customers can use BLIK to purchase crypto directly.

Buying crypto and depositing cash are recorded as separate entries in that guide, so Germany’s absence from the card deposit list speaks to account funding rather than purchasing. To determine whether a card can be used to buy crypto, the purchase column is the relevant one.

Kraken’s support documentation offers a comparable illustration. Dutch residents can fund their accounts in euros via iDEAL, while withdrawals must go through a different method. Such gaps often trace back to how an exchange has structured the movement of money between a customer’s bank and its own platform.

Article 70(4) allows an exchange to provide associated payment services in-house or through a partner, so long as whichever party handles the payments holds the necessary authorization. The exchange must identify the provider and disclose the applicable terms to customers.

MiCA also imposes distinct obligations governing how firms grant access to crypto services. Article 76 requires trading platforms to apply objective, non-discriminatory access rules and proportionate participation criteria.

Their fees must likewise be transparent, fair, and non-discriminatory. Article 77 addresses situations in which a provider trades crypto directly with customers using its own capital. It obliges the provider to publish a non-discriminatory policy setting out whom it serves and what conditions customers must satisfy.

Guidance issued by the European Securities and Markets Authority (ESMA) clarifies that once a customer meets the published conditions and an order becomes final, the provider must execute it.

Establishing whether a provider has failed those duties would require comparing customers requesting the same regulated service from the same legal entity, accounting for eligibility criteria and any mandatory compliance checks.

Coinbase’s card deposit options in Germany and Italy, and Kraken’s iDEAL rules, reveal which payment methods are supported. That is only a fragment of the evidence such a comparison would demand.

Refusing an otherwise accessible EU bank account purely because its IBAN originates in another member state can constitute IBAN discrimination under SEPA rules, though demonstrating it requires proof that a provider rejected an eligible account on that basis. The public guides indicate which local payment methods each exchange supports.

One crypto app can sit on top of several sets of rules

Moving between trading, payments, and rewards within a single app can mean dealing with a different legal entity on each screen.

Kraken’s European Economic Area terms, effective Oct. 14, place its core crypto services with an Irish MiCA-authorized entity. A separate Irish company handles electronic money, and a Cypriot investment firm supplies derivatives and xStocks. The same agreement sets out distinct terms for staking and margin trading.

Coinbase’s European migration notice describes an analogous division. Coinbase Luxembourg assumed responsibility for crypto services under its MiCA authorization, while Coinbase Ireland continued to provide electronic money services.

Both balances remain visible in a single account even though one company is accountable for the cash and another delivers the crypto services. Each authorization extends only to the entity holding it and to the activities that entity has been approved to conduct.

Staking illustrates how the strength of protections can hinge on what a provider does with a customer’s assets. MiCA contains no standalone staking regime, but where a provider holds a customer’s crypto or private keys while staking on their behalf, that custody activity falls within MiCA’s authorization and custody requirements.

The European Commission set out how this operates in guidance published via ESMA. ESMA has separately cautioned that when a regulated firm markets other products alongside its licensed services, customers may wrongly assume those products carry equivalent protections.

Article 66 requires firms to describe their services accurately, using fair and intelligible information that does not mislead. In Revolut’s Hungarian case, anyone reading the outdated notice is left uncertain whether the suspension persists and, if it does, what now justifies it given Hungary’s repeal of the validation rule.

Assessing that notice under MiCA would require a regulator to establish what Revolut currently offers in Hungary and the reason for any continuing restrictions.

Some corners of the European market already function identically across borders. Kraken’s European restrictions page applies certain limits on assets and rewards to customers across the European Economic Area as a single group. Hungarian customers trying to determine whether they can resume trading face a different obstacle.

The legislation behind the shutdown no longer exists, but the answers those customers need are exchange-specific: whether their account will be accepted, how they can fund it, and which company will hold their assets once they do.

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