Last reviewed: 9 November 2026 · Regulatory Gate · General information, not legal advice

Short answer. A UAE firm cannot provide crypto-asset services to EU clients without MiCA authorisation, unless the client comes to it entirely on its own initiative. To serve the EU, you need an authorised entity in a Member State. MiCA has applied in full since 30 December 2024, and the transitional period for existing service providers ended on 1 July 2026 (MiCA, Articles 143 and 149).

What MiCA requires

  • Authorisation. No one may provide crypto-asset services in the EU without authorisation as a crypto-asset service provider. Some financial firms, such as banks and investment firms, can add these services instead (Article 59).
  • An EU base. An authorised provider needs a registered office in a Member State and its place of effective management in the EU. At least one director must live in the EU (Article 59).
  • One licence across the EU. An authorised provider can serve other Member States by notifying its home regulator (Article 65).

The reverse solicitation exception

  • The client must act alone. Authorisation is not needed where an EU client starts the service at its own exclusive initiative (Article 61).
  • Any solicitation ends it. If you, or anyone acting for you, solicit EU clients by any means, the exception falls away. A contract clause or disclaimer saying otherwise does not help (Article 61).
  • No upselling. A client's approach does not let you market new types of crypto-assets or services to that client (Article 61).
  • ESMA reads it narrowly. ESMA calls it a "narrow reverse solicitation regime" (ESMA statement). Its guidelines set out what counts as soliciting (ESMA guidelines).

Issuing tokens to EU investors

  • E-money tokens. Only an authorised credit institution or electronic money institution may offer them to the public in the EU (Article 48).
  • Asset-referenced tokens. The issuer must be established in the EU and authorised, or be a credit institution (Article 16).
  • Other crypto-assets. The offeror must be a legal person with a compliant white paper (Article 4). A firm with no EU presence deals with the regulator where it first offers the tokens, or first seeks admission to trading (Article 3).

The grace period is over

Firms already serving clients under national law could continue only until 1 July 2026 (Article 143). On 23 June 2026, ESMA told unauthorised firms to wind down EU activity in an orderly way and stop onboarding new EU clients. It also said non-EU firms cannot provide MiCA services to EU clients or solicit them (ESMA statement).

Where to start

  1. List your EU clients and how each one first came to you.
  2. Stop any marketing that reaches EU audiences until you are authorised.
  3. If the EU matters to your business, choose a Member State and plan for authorisation there.

Serving EU clients from the UAE? Book a call with Regulatory Gate.