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Reverse Solicitation Under MiCAR – What Third-country Providers Need To Bear In Mind
As the EU's Markets in Crypto-Assets Regulation (MiCAR) becomes fully applicable on 1 July 2026, third-country crypto-asset service providers face critical decisions about market access. Article 61's 'reverse solicitation' exception offers a narrow pathway for serving EEA clients without authorisation, but ESMA's guidelines reveal strict conditions that may catch many providers off guard.
Niedermüller Attorneys