European Crypto Initiative

EUCI

L’association a pour but désintéressé de promouvoir : - Les réseaux de valeur ouverts. - Les crypto-actifs ou actifs numériques. - L’innovation. - L’éthique. - Une réglementation équilibrée. Afin de réaliser ce but désintéressé, l’association a pour objet les activités qui suivent, tant en Belgique qu’à l’étranger, pour compte propre ou compte de ses membres : ● Travailler sur les développements politiques qui ont un impact sur le secteur des blockchains publiques, la technologie open source et les actifs crypto décentralisés, ● S'engager avec les législateurs et les régulateurs au niveau européen pour promouvoir les valeurs de l'EUCI et ses membres, ● Éduquer et diffuser du matériel éducatif destiné aux législateurs et aux régulateurs afin de mieux comprendre les valeurs que nos membres défendent.

Lobbying Activity

Response to 28th regime – a single harmonized set of rules for innovative companies throughout the EU

30 Sept 2025

The complete response can be found in the attached file. ---- The European Crypto Initiative (EUCI) and its members welcome the European Commissions proposal for a 28th Regimean optional, harmonised corporate legal framework aimed at supporting innovative companies, including start-ups and scale-ups, across the Single Market. We see this initiative as a timely and strategic step toward overcoming long-standing legal fragmentation in EU company law and creating conditions that enable cross-border innovation, investment, and growth. It is particularly relevant for companies operating in emerging digital sectors such as blockchain infrastructure, crypto-assets, and decentralised identity systems, which continue to face inconsistent treatment under national frameworks. While the consultation does not explicitly reference blockchain technologies or crypto-asset service providers, the underlying objectives of the 28th Regime, such as simplifying company formation, enhancing digital tools, and facilitating capital formation, are directly aligned with the needs of blockchain-based organisations, digital-native projects, and companies. We encourage the Commission to explicitly consider the blockchain ecosystem as part of the new digitalisation tooling envisioned under the initiative. Blockchain technologies serve as foundational infrastructure for verifiable computation, digital identity, and, to some extent, automated legal execution. Recognising their role would bring the 28th Regime in line with other strategic EU initiatives such as the European Digital Identity Framework, the Data Union Strategy, and the regulatory pillars of MiCA, DORA, and the DLT Pilot Regime, among others. One of the most promising features of the proposal is its digital-by-default approach, including the use of once-only data sharing across national registers, the European Unique Identifier (EUID), and the forthcoming EU Business Wallet. These tools represent the potential emergence of a shared corporate identity infrastructure. This is highly relevant for blockchain projects building decentralised identity, verifiable credential systems, and smart contract-based entity formation tools. A technology-neutral, standards-based approach that accommodates these use cases would help make the 28th Regime future-proof and interoperable with both Web2 and Web3 ecosystems.
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Response to Savings and Investments Union

7 Mar 2025

The European Crypto Initiative (EUCI) appreciates the opportunity to contribute to the European Commission's consultation on the proposed Savings and Investments Union. The crypto industry has experienced remarkable growth, evolving from a niche market to a significant component of the global financial ecosystem. It can play an important role in achieving these objectives by offering alternative investment opportunities and novel financing mechanisms in a now-controlled environment with the recent adoption of MiCA. Integrating crypto-assets into the SIU can substantially advance the Unions strategic objectives: Supporting SME Financing: Following the adoption of the MiCA regulatory framework, startups and SMEs can leverage investment vehicles such as compliant token sales to access funding beyond traditional banking channels, thereby fostering entrepreneurship and economic growth. Increasing retail investor participation: According to market studies, approximately 20% of Gen Z investors and 22% of Millennials are more inclined to invest in alternative assets like cryptocurrencies compared to their older counterparts. Furthermore, Gen Z individuals begin their investment journeys at an average age of 19, significantly earlier than previous generations. By integrating regulated crypto-assets into the SIU, the EU can capture this younger investor base, providing them with accessible, safe and compliant investment opportunities while fostering a culture of financial literacy and inclusion. Achieving greater digitisation through tokenisation: The process of tokenising traditional assetssuch as real estate, stocks, or bondsinto digital tokens on a blockchain can enhance liquidity, reduce transaction costs, and broaden access to investment opportunities. This democratisation of asset ownership aligns with the SIUs goals of increasing returns on savings and widening financing avenues for businesses while simultaneously lowering costs and increasing overall efficiency. Certain challenges must also be addressed: Regulatory Consistency: As previously highlighted in our Single Market Strategy Consultation response (https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14475-Single-market-strategy-2025/F3514423_en), divergent implementation of MiCA across member states risks undermining market integrity. We are calling for a more harmonised approach to implementation and supervision, which is essential to capitalise on Europes leadership position by maximising MiCAs benefits and ensuring a level playing field for all market participants. Education and Financial Literacy: Educating citizens, particularly younger investors, about crypto-assets will empower them to make informed investment decisions and participate more actively in digital finance markets. Therefore, educational initiatives to enhance financial literacy are crucial for the responsible adoption of crypto-assets. The EU can bolster its competitive position by aligning with global best practices: Alternative Asset Management: Institutional investors worldwide are incorporating crypto-assets to diversify portfolios and manage risk. The EU should facilitate similar options to ensure that European investors have full access to all available opportunities. Profitability of Crypto Investments: Studies have shown that cryptocurrency investors can generate significant profits, indicating the overall profitability within this market. This, combined with the regulated nature of the crypto market in the EU and the access to high-level crypto investment advisory services, has the potential to lead to a secure and profitable investment ecosystem. Therefore, integrating crypto-assets into the SIU will strengthen the EUs financial innovation, competitiveness, and inclusivity. Furthermore, a harmonised approach has the potential to attract investment, empower younger generations, and ensure that the EU remains a global leader in digital finance.
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Response to Single Market Strategy 2025

30 Jan 2025

EUCI Response to Single Market Strategy 2025 Consultation The European Crypto Initiative (EUCI) welcomes the opportunity to contribute to the European Commissions consultation on the Single Market Strategy 2025. As representatives of the European crypto industry, we recognise the single markets crucial role in fostering innovation, competitiveness, and growth. However, we highlight key challenges related to the treatment of crypto-assets, particularly under the Markets in Crypto-Assets Regulation (MiCA). A competitive European digital economy, as outlined in the Draghi report, is key. The strong regulatory framework introduced during the last mandate provides a solid foundation; new rules should be built to strengthen Europes global position. MiCAs adoption is a milestone in regulatory clarity and market harmonisation. However, inconsistent implementation across member states undermines the single markets integrity and threatens the EUs leadership in digital finance. Key concerns include: Diverging supervisory practicesvarying interpretations and resource allocation risk eroding MiCAs benefits, hampering innovation. Uneven grandfathering periodsdisparities create uncertainty, complicating compliance and operational planning. Market entry barriersaccess to essential financial services (e.g., insurance, banking, external auditors) remains a challenge. This is a crucial test for the EU. The crypto-asset market is still developing, and MiCAs success will shape its integration into the broader financial strategy. A well-executed implementation will also set a precedent for future regulations, including AMLAs work and the full application of the AML package. Financial crime prevention, education, and financial literacy should remain core priorities in this broader framework. Additionally, the EU must recognise the role of DLT-based applications in deepening market integration. Tokenisation, for instance, can boost EU capital markets by enhancing liquidity, reducing transaction costs, and broadening access to financial productsaligning with the Savings and Investments Unions objectives. For DLT to drive integration, market infrastructures must be technologically neutral, allowing open use of permissionless blockchains. As global regulatory approaches evolve, particularly in response to shifts in U.S. policy, Europe must act decisively to maintain leadership. Failure to address these challenges risks ceding digital economy dominance to other jurisdictions. To strengthen the single market and ensure MiCAs success, the EUCI recommends: Clear, uniform guidelines for consistent MiCA application across member states. Enhanced coordination among national competent authorities to streamline passporting and address transitional challenges. Targeted support for member states to facilitate effective MiCA implementation. Regular industry engagement to address emerging regulatory issues proactively. By tackling these challenges, the EU can reinforce its single markets integrity and cement itself as a global leader in crypto-asset innovation. EUCI remains committed to supporting the Commissions efforts and stands ready to provide further input on these critical issues.
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