MiCA applies to two distinct actor types: crypto-asset service providers (CASPs) and token issuers. CASPs are defined as entities providing crypto-asset services professionally and include ten service categories such as custody, operating trading platforms, exchanging crypto-assets, executing orders, placing crypto-assets, and receiving and transmitting orders. Token issuers face different obligations, including requirements around white papers. ESMA’s public register shows EU-compliant white papers filed by token issuers incorporated in the British Virgin Islands, Cayman Islands, Panama, and Singapore since MiCA took effect, without incorporating EU entities. Examples include Bybit’s BVI parent with an Austrian MiCA-licensed subsidiary, OKX’s Seychelles top with a Malta-authorized subsidiary, and Crypto.com’s Singapore operations with a licensed Maltese EU-facing entity.
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