ESMA Q&A - Lending services under MiCA
ESMA Q&A - Lending services under MiCA In its Q&A 2883 of 18 June 2026, ESMA clarifies that a CASP may offer crypto-asset lending services, but that this activity remains outside the scope of MiCA: it is covered neither by the CASP's authorisation nor by the European passport. The CASP nevertheless remains subject to the general principles of Article 66 (acting in the best interests of clients, fair and not misleading information) and must clearly separate its lending offering from its authorised services. Using clients' assets requires express, lending-specific consent; MiCA's protections (notably segregation) cease to apply to lent assets; and lending income must mainly accrue to the client, a framework that calls many "Earn"-type programmes into question.
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Cécile Henry
Regulatory and compliance expert at Seqlense. Cécile authors every Seqlense Note — bringing hands-on experience and a pragmatic approach to regulatory analysis, with a focus on real operational impact rather than abstract theory. Her work covers French, Luxembourg and Belgian regulators, EU frameworks (MiCA, DORA, AML), and the operational reality of compliance in financial services and crypto.
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