Spain’s CNMV Unveils Detailed Q&A: Your Roadmap to Navigating EU’s MiCA Rules
Spain just handed crypto firms a rulebook. The National Securities Market Commission (CNMV) dropped its comprehensive Q&A on implementing the EU's landmark Markets in Crypto-Assets (MiCA) regulation—and the clock is ticking.
Decoding the Rulebook
Forget vague guidelines. The CNMV's document cuts through the regulatory fog, translating MiCA's complex mandates into actionable steps for exchanges, wallet providers, and token issuers operating in Spain. It tackles licensing, stablecoin reserves, and consumer disclosures head-on.
The Compliance Countdown Begins
This isn't theoretical. The Q&A sets a clear runway for the full application of MiCA rules by December 2025. Firms that drag their feet risk being sidelined in one of Europe's key markets—a costly mistake in a sector where regulatory approval is becoming the new competitive moat.
A Blueprint or a Straitjacket?
The guidance provides much-needed certainty, a rare commodity in crypto. Yet, some will chafe at the detailed compliance burden, a classic move by traditional finance gatekeepers who love process almost as much as they love their fees. Whether this framework fuels responsible innovation or simply protects legacy players remains the trillion-euro question. One thing's clear: in Europe's new crypto order, playing by the rules is no longer optional.
CNMV updates existing crypto investment laws
In its announcement, the CNMV changed two of its existing Q&A documents: one concerning collective investment institutions (IICs) and venture capital entities (ECRs), and another covering applications of the EU’s Markets in Financial Instruments Directive II (MiFID II).
A new section specifically dedicated to MiCA has also been created, alongside that for collective investment institutions, including “Instituciones de Inversión Colectiva de Inversión Libre” (IICIL), where the regulator clarified how limits will be applied to periodic redemptions in vehicles investing in “evergreen funds.”
Spain’s adoption of MiCA will expose certain retail investors to crypto through free investment funds as the government seeks to expand access to digital asset markets in tandem with laws that protect investors.
Besides the MiCA regulatory language, venture capital entities now have more transparency obligations under the CNMV’s guidance. These institutions must provide clear information to investors about their financing operations and associated leverage, alongside instructions on how fees should be calculated when based on the committed capital of the entity.
On the MiFID II implementation front, one update discusses when promotional activities by influencers or collaborators are considered client solicitation, a reserved activity under EU rules. Influencer’s activities will be classified as marketing if compensation is issued according to the volume or number of clients acquired, or if the collaborator interacts with followers to establish regular client relationships, among other factors.
Another update displays the requirements for bilateral over-the-counter derivatives issued to clients for hedging, defining conditions necessary for these products to comply with regulatory standards and protect investors. The new MiCA Q&A has the regulator’s criteria for processing authorization and notification applications from crypto service providers.
As seen on the CNMV’s public notice, the transitional period for MiCA rules will last until July 1, 2026. Those entities intending to request authorization must submit their applications well in advance to allow regulators and firms to adjust their systems, reporting mechanisms, and compliance processes ahead of its full enforcement in the second half of the coming year.
Poland reintroduces MiCA-aligned digital asset bill after several failures
Spain’s plan to adopt MiCA for digital assets comes just over a week after another member of the EU, Poland, reintroduced digital asset legislation brought down by an earlier presidential veto.
Polska2050, which is part of the ruling coalition in the lower house of parliament, launched a second attempt at passing MiCA-aligned legislation on December 8, less than a week after it failed to overturn President Karol Nawrocki’s interdiction, Cryptopolitan reported.
The new draft dubbed Bill 2050 was coined by Polska2050 member Adam Gomoła “an improved” successor to the vetoed Bill 1424, initially introduced by Prime Minister Donald Tusk’s government in June.
Government spokesman Adam Szłapka, however, said that “not even a comma” had changed from the previous version. Both bills designate the Polish Financial Supervision Authority as the main regulator for digital assets and protector of consumers.
President Nawrocki vetoed Bill 1424 on December 1, citing discrepancies that posed “a real threat to the freedoms of Poles and the stability of the state.” During his 2025 presidential campaign, Nawrocki promised to prevent regulations that could restrict investment freedoms in emerging asset classes.
In other related news, London-based private company Byrrgis announced yesterday it has obtained an EU MiCA license, enabling it to operate as a fully regulated financial platform. The license clears the way for Byrrgis to launch on January 15 and has prompted the platform to open a waitlist for early user access.
The firm completed an application process to acquire the EU license and is building up to a CASP level 3 certification, the highest standard for blockchain firms within the European trading bloc.
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