Operating a platform that trades only Bitcoin — no stablecoins, no asset-referenced tokens, no other crypto-assets — does not place you outside MiCA's scope. Regulation (EU) 2023/1114 (MiCA) applies to the provision of crypto-asset services, not to specific token types. If you operate an exchange or custody service for Bitcoin within or into the EEA, you are a crypto-asset service provider (CASP) and you require authorization from a competent authority in a member state unless an exemption applies.
The misconception arises because much early commentary focused on MiCA's stablecoin-specific obligations — white-paper requirements for asset-referenced tokens (ARTs) and e-money tokens (EMTs), reserve rules, redemption rights. Those obligations do not apply to Bitcoin because Bitcoin is neither an ART nor an EMT. But the same regulation lists ten categories of crypto-asset service in Article 3(1)(15), and nine of them apply regardless of token type. Operating an exchange, providing custody, or executing orders on behalf of clients are crypto-asset services whether the asset is Bitcoin, Ether, or a proprietary token.
Which crypto-asset services apply to Bitcoin-only platforms
Article 3(1)(15) MiCA defines ten crypto-asset services. A Bitcoin-only platform typically provides one or more of the following:
| Service (Article 3(1)(15) reference) | Applies to Bitcoin | Common on Bitcoin-only platforms |
|---|---|---|
| (a) Custody and administration of crypto-assets on behalf of clients | Yes | Custodial wallet, user balances held by the platform |
| (b) Operation of a trading platform for crypto-assets | Yes | Order book, matching engine, exchange frontend |
| (c) Exchange of crypto-assets for funds | Yes | Fiat on-ramp / off-ramp (EUR, USD to BTC) |
| (d) Exchange of crypto-assets for other crypto-assets | Yes | BTC/ETH pair, if the platform lists >1 asset |
| (e) Execution of orders for crypto-assets on behalf of clients | Yes | Broker model, agency execution |
| (f) Placing of crypto-assets | Yes | Primary distribution, rare for Bitcoin |
| (g) Reception and transmission of orders for crypto-assets on behalf of clients | Yes | Order-routing platforms |
| (h) Providing advice on crypto-assets | Yes | Investment advice on Bitcoin allocation |
| (i) Providing portfolio management on crypto-assets | Yes | Managed Bitcoin portfolios |
| (j) Providing transfer services for crypto-assets on behalf of clients | Yes | On-chain withdrawal service |
A platform that holds user Bitcoin (service (a)), operates an order book (service (b)), and allows users to buy Bitcoin with EUR (service (c)) provides three crypto-asset services. Each triggers the authorization requirement in Article 59 MiCA. The fact that the platform lists no stablecoins is irrelevant to this determination.
Why stablecoin-specific rules do not apply
MiCA distinguishes between obligations that apply to all crypto-assets and obligations specific to ARTs and EMTs. Bitcoin is not an ART because it is not asset-referenced as defined in Article 3(1)(3) — it does not maintain a stable value by reference to another value or right or a combination thereof. It is not an EMT under Article 3(1)(4) because it is not denominated in a fiat currency unit and does not purport to maintain a stable value by reference to a fiat currency.
Consequently, a Bitcoin-only platform does not have obligations under:
- Article 19 (ART white paper)
- Article 48 (EMT white paper)
- Article 36 (own funds for significant ART issuers)
- Article 45 (reserve of assets for ARTs)
- Article 56 (reserve of assets for EMTs)
- Article 52 (redemption rights for EMT holders)
These are issuer obligations, and Bitcoin has no issuer in the MiCA sense. But the platform providing exchange or custody services for Bitcoin remains a CASP and must comply with Title V MiCA (authorization and operating conditions for CASPs) and Title VI (prudential and conduct-of-business rules).
Authorization requirement and threshold
Article 59(1) MiCA requires any person who intends to provide crypto-asset services professionally in the Union to be authorized as a CASP by the competent authority of its home member state. "Professionally" is not numerically defined in MiCA; member states apply interpretive guidance from national law and supervisory practice. Operating a trading platform accessible to the public, holding client assets, or receiving funds for crypto-asset exchange are routinely considered professional activities regardless of volume.
No de minimis exemption exists. A Bitcoin-only exchange with ten users per month and €5,000 in monthly volume is subject to the same authorization requirement as a multi-asset platform with 100,000 users, if both provide the same services. The competent authority may apply proportionate supervision after authorization, but the authorization threshold itself does not scale with size.
MiCA entered into force on 29 June 2023 and applied in stages. For CASPs, the authorization requirement applied from 30 December 2024 (Article 143(1)). Firms providing crypto-asset services before that date and having notified the competent authority by 1 July 2024 could continue under the transitional regime in Article 143(3) until 1 July 2026 or until their application was decided, whichever came first. A Bitcoin-only platform established after 30 December 2024 requires authorization before commencing services. One established before 30 December 2024 that did not notify by 1 July 2024 must cease services until authorized.
You can check whether a firm is authorized and for which services at /verify, which reads the live ESMA register under Article 109 MiCA.
Common exemptions and why they rarely apply
Article 4(2) MiCA lists categories of service providers to which the regulation does not apply. None of these exemptions is specific to stablecoins, but none commonly applies to Bitcoin-only exchanges either:
- (a) UCITS management companies and AIFMs authorized under the UCITS Directive or AIFMD, when providing crypto-asset services exclusively in the context of managing UCITS or AIFs. A retail Bitcoin exchange is not managing a UCITS.
- (b) Central securities depositories authorized under the CSDR. A Bitcoin ledger is not a securities settlement system under that regulation.
- (c) Central counterparties and trading venues authorized under EMIR or MiFID II, when providing crypto-asset services exclusively to settle transactions in financial instruments. A Bitcoin-for-EUR exchange is not settling MiFID financial instruments.
- (d) Credit institutions and investment firms already authorized under CRR or MiFID II. These entities may provide crypto-asset services without separate CASP authorization (Article 60(4) MiCA), but this is not an exemption — it is alternative authorization. The firm is still subject to MiCA's conduct-of-business and prudential rules.
- (e) Insurance and reinsurance undertakings under Solvency II, when providing crypto-asset services as part of insurance business. A Bitcoin exchange is not an insurance undertaking.
- (f) Crowdfunding service providers under the European Crowdfunding Service Providers Regulation. A Bitcoin trading platform is not a crowdfunding platform.
- (g) Non-fungible tokens (NFTs) that are unique and not fungible with other crypto-assets (Article 2(3) MiCA). Bitcoin is fungible; one BTC is interchangeable with another BTC of the same value on the same network.
The Article 2(3) NFT carve-out is the most frequently misunderstood. Bitcoin is not an NFT. Even a platform trading a single rare satoshi (as conceived in ordinals-based projects) would argue the satoshi is unique, but the platform service (custody, exchange) would still fall under MiCA if conducted professionally.
Obligations post-authorization
Once authorized, a Bitcoin-only CASP must comply with:
- Article 67 (governance arrangements)
- Article 68 (own funds — €50,000 for custody services, €150,000 for operating a trading platform, plus 3% of average annual operating expenses)
- Article 70 (safeguarding arrangements if providing custody)
- Article 73 (conflicts of interest policy)
- Article 76 (outsourcing framework)
- Article 77 (complaints-handling procedure)
- Articles 78–81 (conduct-of-business rules: fair and honest communication, best execution, prevention of market abuse, order handling)
- Article 84 (publication of prices and fees)
- Regulation (EU) 2023/1113 (TFR) (information accompanying transfers of crypto-assets, applicable from 30 December 2024)
The safeguarding requirement in Article 70 is particularly consequential for Bitcoin custody. The CASP must maintain a register of crypto-assets held for each client, segregate client holdings from its own, and arrange for the timely transfer of crypto-assets to clients on request. Commingling client Bitcoin with the platform's operational wallet or using client deposits for liquidity provision without explicit disclosure and consent would breach Article 70(1) and (2).
Article 68(2) sets own-funds requirements by service category. A platform providing service (a) custody alone must maintain €50,000 in own funds; one providing service (b) operation of a trading platform must maintain €150,000. If the same entity provides both, the higher requirement applies. These are minimum figures; the competent authority may require more under Article 68(6) if it assesses that the firm's risk profile warrants it.
Bitcoin as a 'non-significant' asset
MiCA designates certain ARTs and EMTs as "significant" under Article 43 if they meet thresholds in customer base, transaction value, market capitalization, or interconnectedness (Annex III). Significant tokens are subject to ESMA oversight in addition to national supervision, and issuers face enhanced reserve and capital requirements.
Bitcoin is not an ART or EMT, so the significance framework does not apply. This is sometimes misunderstood as meaning Bitcoin is exempt from MiCA. The correct interpretation is that Bitcoin issuance (to the extent there is an issuer, which MiCA would not recognize) is not subject to the ART/EMT white-paper and reserve rules, but services provided with respect to Bitcoin remain in scope as crypto-asset services.
Interaction with national regimes
Several member states operated national crypto-asset licensing regimes before MiCA: Germany's Kryptoverwahrgeschäft under the KWG, France's PSAN regime under the PACTE law, Italy's registry under Article 17-bis of Legislative Decree 141/2010, the Netherlands' registration under the Wtfv. These regimes continue in parallel with MiCA during the transitional period. After 1 July 2026 (the end of the transitional period under Article 143(3)), national CASP regimes inconsistent with MiCA must be withdrawn, and only MiCA authorization permits the provision of crypto-asset services across the EEA.
A Bitcoin-only platform authorized as a CASP in one member state may passport its services into other member states under Article 64 MiCA, provided it notifies ESMA and the host-state competent authority. A firm authorized in Germany for service (b) operation of a trading platform may, after notification, offer the same service to clients in France, Spain, and all other EEA states without requiring separate authorization in each. The passporting process is the same whether the platform lists only Bitcoin or fifty crypto-assets.
You can review which services a firm is authorized for and in which member state at /verify, or browse all authorized CASPs in a given jurisdiction at /registry/country/{ms} (for example, /registry/country/de for Germany).
Conclusion
Offering only Bitcoin does not remove a platform from MiCA's scope. MiCA regulates crypto-asset services, not crypto-asset types. If you operate an exchange, provide custody, or execute orders for Bitcoin within the EEA, you require CASP authorization under Article 59. The stablecoin-specific obligations in Titles III and IV do not apply, but the authorization requirement and the prudential and conduct-of-business rules in Titles V and VI do. A Bitcoin-only exchange is a CASP in the same way a multi-asset exchange is; the difference lies in which token-level rules apply, not whether service-level rules apply.
The competent authority assesses the application based on the services provided, not the assets listed. A firm that holds client Bitcoin and operates an order book provides services (a) and (b) under Article 3(1)(15), regardless of whether it also lists Ether or stablecoins. The own-funds calculation, the governance arrangements, and the safeguarding obligations are determined by the service category, and those categories are asset-neutral.