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MiCA – ESMA Q&A Distinguishing Execution from reception and transmission of orders

On 14 October 2025, ESMA provided some clarification about how to distinguish crypto- asset services under MiCA and more precisely how to distinguish “execution of order for crypto-assets on behalf of clients” (Article 3(1)(16e), and “reception and transmission of orders for crypto-assets on behalf of clients” (Article 3(1)(16g) from one another.

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