Deciphering the ESMA opinion on MiCAR convergence: broker-dealer models & best execution requirements

Several months following its publication, this paper examines ESMA’s 31 July opinion issued to National Competent Authorities (NCAs) and considers the impacts it is having on those seeking to operate within the parameters of Europe’s Markets in Crypto Assets Regulation (MiCAR). We assess how ESMA's guidance is reshaping the landscape for broker-dealer models, and how best execution requirements will require firms to make operational changes in a rapidly evolving regulatory environment.