Financial Services Perspectives: November 2026 | Beyond MiCA

Licensing opens up the market. Governance, resilience and execution will determine who earns institutional confidence and scale.

Transition from licensing to trust 

For several years, the European digital asset conversation has been dominated by one question: who will secure a Markets in Crypto-Assets ('MiCA') licence first? 

That question is quickly becoming less relevant. As authorisation moves from competitive advantage to market-entry requirement, the real point of differentiation will be harder to obtain and easier to lose: institutional trust. 

A licence is a point-in-time assessment. Supervision is continuous. The firms that succeed in Europe’s next digital finance chapter will therefore be those that can demonstrate, day after day, that governance, resilience and sound decision-making are embedded in how they operate - not simply documented for regulatory approval. A MiCA license may open the door to the market, but it does not automatically create trust.  

MiCA does not operate in isolation. It sits within a broader European framework that includes Digital Operational Resilience Act  ('DORA'), which strengthens operational resilience, Anti-Money Laundering Regulation ('AMLR') and  Authority for Anti-Money Laundering and Countering the Financing of Terrorism ('AMLA') which create a more harmonised approach to combatting financial crime and DAC8 which introduces comprehensive tax reporting obligations for crypto asset service providers. Taken together, these measures signal a decisive shift and create a coherent framework for resilience, financial integrity, transparency, and supervisory consistency across the European Union. Digital asset firms are no longer being assessed only as innovators. They are increasingly expected to meet the standards of established financial institutions. 

In our view, that is a positive development. Innovation may open the door, but trust determines whether a business can secure banking relationships, attract institutional capital, reassure counterparties and scale across borders. Compliance is no longer merely a cost of market access. If it is done well, it becomes a commercial capability. 

Europe’s real advantage lies in its ecosystem

The same principle applies to financial centres. Harmonised rules may make access across the EU more comparable, but they do not make every ecosystem equal. Capital, specialist talent, supervisory credibility, banking connectivity and professional infrastructure tend to reinforce one another. Europe may not produce a single dominant digital asset hub.

Instead, we are likely to see a network of complementary centres, each competing on the depth and quality of its wider financial ecosystem. Germany benefits from the scale and institutional depth of its financial sector. France combines strong political ambition with a clear focus on digital assets and tokenisation. Ireland builds on its internationally recognised financial services industry and global technology presence, while the Netherlands leverages its strengths in payments, market infrastructure, proprietary trading, and financial technology. Malta continues to build on its early digital asset experience as the market matures.   

Each jurisdiction brings distinct strengths while also performing complementary roles within Europe’s broader financial architecture. This diversity may ultimately be one of Europe’s greatest competitve advantages allowing firms to choose the ecosystem that best supports their business model while operating in a harmonised regulatory framework. 

At a time when global regulation for digital assets is fragmented, Europe has achieved something significant with its MiCA regulation, creating a harmonised framework across a large economic market. Markets outside Europe are also strengthening their digital finance frameworks and positioning themselves as attractive centres for digital asset and tokenisation activity. While global businesses must be selective, the differences between the markets will shape where firms invest and scale. Europe offers harmonised access to a substantial market; the United States brings exceptional capital-market depth and liquidity; the United Kingdom retains strong wholesale and professional-services networks; Singapore and Hong Kong provide access to Asian investors and markets; and Dubai continues to invest deliberately in its position as an international digital asset centre. Each starts with a different advantage, but none is guaranteed long-term leadership. 

The decisive task is conversion - turning regulatory clarity, domestic scale or policy ambition into liquidity, infrastructure, institutional participation and specialist expertise that competitors cannot easily reproduce. The regulatory race may determine where firms go first, but market depth will influence where they stay. In that sense, the next phase of competition will be less visible than the licensing announcements, but considerably more important. 

Future of digital finance

Beyond the competitive race lies a more fundamental shift. Digital finance may eventually cease to exist as a separate category. Tokenisation, programmable settlement and regulated distributed-ledger infrastructure are beginning to test how execution, custody, collateral, reporting and compliance might be redesigned within mainstream finance. Initiatives exploring the interaction between distributed-ledger platforms, central-bank money and tokenised commercial-bank deposits suggest that this is moving beyond a purely conceptual debate. 

The opportunity is not merely to place an existing asset on a new technological rail. Programmable infrastructure could reshape the sequence of activities around a transaction, bringing execution, settlement, record-keeping and elements of compliance closer together. That could reduce friction, improve transparency and allow assets or collateral to move with greater speed and precision. It may also alter product economics, treasury arrangements and the role played by intermediaries across the value chain.   

However, efficiency should not be confused with simplicity. Faster or atomic settlement may reduce counterparty exposure while increasing intraday liquidity demands. More responsive collateral movement may improve capital efficiency while transmitting stress more quickly. Smart contracts can embed controls, but they also create dependencies on code, data quality, governance and third-party infrastructure. Technology can change how trust is delivered, but it does not remove the need for legal certainty, accountability, judgement, liquidity or balance-sheet strength. 

For boards and senior leaders, the priority should not be to predict which ledger, settlement asset or market architecture will ultimately prevail. It should be to understand where programmability could alter product economics, operating model, settlement arrangements and the organisation’s place in the value chain. That assessment cannot sit solely with a digital assets or innovation team. Technology, operations, finance, treasury, legal, compliance, risk and assurance all need to shape the response with clear ownership and an honest view of both oppportunity and exposure.  

Assurance will also need to evolve. As more financial logic is embedded in technology, organisations will require confidence not only in conventional financial controls, but also in the design and operation of code-based processes, data flows, access arrangements, governance protocols and third-party dependencies. The key question will no longer be whether a technology is innovative, but whether the overall system is reliable, explainable and capable of operating under stress.  

The leadership imperative: govern for the next phase

MiCA may mark the end of Europe’s initial licensing race, but it is only the beginning of the institutional one. Europe’s opportunity is not simply to regulate first. It is to demonstrate that innovation and trust can compound rather than compete, and that digital infrastructure can be integrated into finance without recreating old fragmentation or weakening accountability.  

The central takeaway is clear: digital asset strategy can no longer sit at the edge of an organisation as a standalone innovation initiative. It is becoming part of financial strategy itself. The firms and financial centres that recognise this early – while remaining disciplined about governance, resilience and execution – will be best placed not merely to respond to the next phase of digital finance, but to shape it.

Click here to access the full PDF version of our Financial Services Perspectives briefing - November 2026.