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.
About the author
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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