MiCA On Best Execution in Crypto - Is the Market Ready?
Industry Voice
Categorised: Channels, Crypto, The Stream | Tags: best execution, CASPs, crypto, MiCA, regulationPosted by Colin Lambert. Last updated: April 29, 2026
From July 1, 2026, EU crypto brokers can no longer merely state a best execution policy. They have to prove it.crypto
For years, best execution in crypto has been a matter of policy. Brokers documented their approach, listed the venues they used, and filed the paperwork. Whether the policy was actually followed, and whether clients consistently received the best available price, was harder to demonstrate. That changes on July 1, 2026.
With the end of MiCA’s transition period, the regulation of crypto-asset markets moves from principle to enforcement. Crypto-asset service providers (CASPs) operating in the EU can no longer rely on the grace period that allowed for gradual compliance. Firms without full regulatory authorisation risk being forced to cease all or part of their crypto services in the EU. Administrative penalties reach EUR 5 million or 3% of total annual turnover, whichever is higher.
Similar to the number of players, EUR-denominated trade volume is also higher, specifically since the end of 2024.
From Principles to Proof
MiCA does not invent a new regulatory logic for crypto. It applies the same framework that MiFID II established for traditional securities markets: regulated market entry, conduct-of-business rules, and mandatory transparency. Under Article 78 of MiCA, best execution for CASPs now explicitly requires demonstrable consideration of price, cost, speed of execution, likelihood of settlement, and conditions for securing or holding crypto-assets.
The difference between a policy statement and a regulatory obligation is enforcement. Traditional finance already shows what that looks like. The AMF’s Sanctions Committee, in its August 2021 decision, identified failures in best execution policy controls at Amundi Asset Management and imposed financial penalties of up to EUR 25 million. That decision was made under MiFID II. MiCA follows the same logic.
Why Crypto Makes This Harder
Best execution in traditional equity markets is already demanding. Crypto makes it structurally more complex. Price discovery for any given cryptocurrency is fragmented across more than 100 exchanges globally, operating continuously across every time zone with no consolidated tape and no single authoritative reference price. EU-based CASPs face an additional constraint: under MiCA, only a defined subset of those venues are compliant and therefore eligible for execution. That narrows the pool while the market itself remains global and fragmented.
Demonstrating best execution in this environment requires continuous, 24/7 visibility into order books and market conditions across every relevant venue. Not periodic snapshots, but tick-level data capturing every price movement in real time. It also requires storing that data at scale: Article 76 of MiCA requires CASPs to retain records for at least five years, and the data volumes involved can quickly reach petabytes. Firms must be able to reconstruct, retrospectively and on regulatory request, exactly what market conditions looked like at the moment any order was executed, and demonstrate that the outcome was optimal.
Post-Trade Analytics as the New Compliance Layer
The practical burden falls heavily on post-trade infrastructure. Achieving a good execution price is necessary but not sufficient. CASPs must be able to evidence that the outcome was optimal relative to what was available at the time. That distinction matters under regulatory scrutiny.
This is where independent, auditable data becomes structurally important, not as a compliance formality but as the mechanism through which best execution claims can be substantiated. A broker relying on its own internal data to demonstrate consistent best routing is in a weaker position than one using a third-party benchmark sourced from comprehensive, independently verified market data. Regulatory defensibility depends on the independence and methodology of the pricing reference, not just the completeness of the records.
The Segmentation That Follows
July 1 will accelerate a market divide that is already forming: between players that can demonstrate institutional-grade execution quality with auditable evidence and those that cannot. Firms equipped to show regulators exactly how each order was handled, against what market conditions, and why the outcome met best execution standards will carry a compliance advantage that compounds over time.
EU crypto markets are growing. EUR-denominated trading volumes have been climbing steadily since late 2024, and the number of market participants falling within MiCA’s scope is expanding in parallel. The commercial stakes of best execution compliance are rising alongside the regulatory ones. The deadline is fixed. The data required to meet it is something firms either already have or urgently need to build.
By Thomas Probst, Research Analyst, Kaiko
