Financial regulators in France, Austria and Italy urged the European Union's top markets watchdog to start supervising major crypto companies directly and tighten the bloc's rules, after identifying disparities in how crypto regulations are being implemented.
The EU began rolling out its Markets in Cryptoassets regulation in late 2024, requiring crypto companies to secure a license in at least one EU member state in order to offer their services across the bloc.
In a position paper published on Monday, France's Autorité des Marches Financiers, Austria's Finanzmarktaufsichtsbehörde and Italy's Commissione Nazionale per le Società e la Borsa said that approach had revealed "major differences" in how each country is supervising companies, allowing businesses to take advantage of varying approaches. The regulators suggested transferring oversight powers for the sector's largest businesses to the European Securities and Markets Authority.
"The experience of MiCA's first few months in application also shows that supervisory convergence between national authorities quickly reaches its limits, and is not sufficient to guarantee uniform application of standards within the EU," the AMF, FMA and CONSOB said in the paper.
ESMA didn't immediately respond to a request for comment.
Bloomberg News reported in March that EU crypto regulators were scrutinizing the use of a service offered by crypto exchange OKX by North Korean hackers to launder some of the proceeds from a $1.5 billion heist on trading platform Bybit. Several regulators urged ESMA and OKX's EU regulator, the Malta Financial Services Authority, to take action against OKX at a March meeting, including possibly rescinding its permit to operate in the bloc.
In June, ESMA said it had completed a fast-track peer review of processes at Malta's MFSA, through which major exchanges such as Gemini and Crypto.com have also received licenses since the start of 2025. The review identified shortcomings in Malta's approval process for one unnamed provider, questioning the timing of Malta's decision to grant a license while "material issues" including enforcement actions remained unresolved.
In Monday's paper, the three regulators said they could be forced to resort to taking precautionary measures in order to prevent risks to national investors. Such provisions could include challenging a firm's right to passport services into that country. The regulators also called on legislators to strengthen rules for global platforms servicing the EU through local partners, on cybersecurity practices and on token offerings.