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More than a decade and a half since Bitcoin’s whitepaper made its debut, the rules governing the asset (as well as the crypto as a whole) have had to face bottlenecks at pretty much every nation’s doorstep.
And even though Europe, the United States, and the United Arab Emirates claim to be running “mature” crypto regimes, each of them collides not only with one another but, many a time, with their own existing rule sets.
To this point, the Financial Stability Board, an international body that monitors the global financial system, recently found that the state of crypto cooperation among all major nation-states is extremely fragmented and insufficient.
Europe’s Rulebook Is Already Back for Edits
Last month, the transitional period under the EU’s Markets in Crypto-Assets (MiCA) Regulation ended, and any crypto-asset service provider that still lacked a license had to wind down its EU operations immediately.
However, just weeks earlier, the European Commission opened a consultation asking whether MiCA itself needed rewriting. That review has since been extended through September 30, after it became increasingly clear that the rulebook’s original scope failed to adequately address aspects such as stablecoin interest, DeFi, staking, and tokenized deposits.
The stablecoin market, in particular, has been under intense regulatory scrutiny because, as of mid-August, only 23 issuers hold full MiCA authorization for e-money tokens, spread across just 13 of the bloc’s member states. And since there is still no equivalent regulatory regime for stablecoin issuers based outside the EU, it cuts European exchanges off from the dollar liquidity that trades elsewhere.
At the same time, Revolut’s August rollout of EURR shows that MiCA is beginning to produce a more mainstream euro-stablecoin market. EURR, issued by Stripe-owned Bridge and distributed through Revolut, gives eligible European users a euro-denominated route between fiat, crypto and external wallets without taking on dollar exposure.
Washington’s Holdup Was Never About Market Structure
America’s answer to MiCA, aka CLARITY, has been in the same boat for much of the year, having stalled over questions that have little to do with how crypto markets function but with ethics.
To this point, detractors have cited Trump’s financial disclosures, in which he reported his 2025 crypto income at roughly $1.4 billion, with $635 million of it from meme coin royalties alone. As a result, discussions have moved from creating a holistic cross-border infrastructure to enforcing bans on officials sponsoring digital assets.
A quick look at Polymarket now shows that the odds of CLARITY being signed into law this year have collapsed to roughly 13%, meaning that Bitcoin might spend at least another full year without a U.S. market-structure law.
Institutions that have therefore sought exposure to the market have had only two avenues to do so: ETFs and treasuries (DATCOs).
Finally, the UAE has routinely been hailed as evidence that fast, clear crypto rules are possible. In this regard, roughly 100 firms currently hold active virtual asset licenses across the country’s five separate regulators (i.e., Dubai’s VARA, Abu Dhabi’s ADGM and FSRA, the DIFC’s DFSA, the federal CBUAE, and the Capital Market Authority).
Despite this, none of the five licenses travel/translate automatically with one another, a split that is again exposed by stablecoins. For instance, VARA regulates tokens like USDT, USDC, etc as a special fiat-referenced virtual asset category that has its own reserve and disclosure rules. ADGM, on the other hand, folds stablecoins directly into its existing financial-services rulebook.
In other words, neither recognizes the other’s paperwork.
The Right Intention Is There, but Zero Interoperability Persists
Earlier this year, PwC reviewed more than fifty jurisdictions and found that crypto rulemaking had accelerated almost everywhere, shifting from writing rules to enforcing them. But with each region routinely tweaking its local frameworks by adding its own standards, the sum of all that good-faith effort has been an asset class that needs three legal opinions, three licensing strategies and three compliance budgets just to operate seamlessly.
For listed treasury companies and exchanges operating in these regions, legal spend, licensing delays, etc., can pile up in ways that become tangible extremely quickly. A single mutual-recognition arrangement, even between just two legal entities, therefore stands to reduce overheads more than any new rulebook written from scratch. The next competitive advantage in crypto regulation may not come from writing more rules, but from making existing frameworks work across borders.
Source: hackernoon.com