CEPS: Centre for European Policy Studies and EU Crypto Implementation

Brussels runs on implementation detail. The political decisions about crypto regulation — to create MiCA, to establish the DLT Pilot Regime, to give AMLA supervisory authority over crypto AML — are made at the level of the Council, the Parliament, and the Commission. But the decisions that determine how those political choices actually function in practice — what licensing conditions mean operationally, how supervisory cooperation between national competent authorities works, what AMLA’s supervisory methodology will look like — are made in technical working groups, Level 2 regulatory technical standard processes, and supervisory guidance documents where detailed analytical input matters.

The Centre for European Policy Studies occupies this technical space. Founded in 1983, CEPS has built its reputation on granular EU regulatory analysis — the kind of detailed engagement with directive text, implementing regulation proposals, and supervisory guidance that complements rather than duplicates the macro-level economic analysis that Bruegel provides.

MiCA Implementation: The Detail Work

MiCA’s implementation across 27 EU member states is not automatic. The framework requires each member state to designate a national competent authority for crypto asset service provider supervision, establish licensing procedures, build supervisory capacity, and coordinate with ESMA on cross-border cases. The pace and quality of this implementation varies substantially across member states — and the variation matters for firms deciding where to establish their EU regulatory home.

CEPS has tracked MiCA implementation at the national level with the kind of comparative detail that is genuinely useful for compliance practitioners. Which national competent authorities have published licensing guidelines? Which have proactively engaged with industry to clarify requirements? Where are supervisory approaches most and least accommodating to established firms? This comparative implementation mapping does not appear in ESMA’s official guidance or in Bruegel’s macro-level analysis, but it is exactly what legal and compliance teams making jurisdiction choices need.

The DLT Pilot Regime has been another area of granular CEPS engagement. The regime was designed to allow experimentation with blockchain-based trading and settlement — a temporary exemption from certain MiFID and CSDR requirements — but its uptake has been limited. CEPS analysis has examined both why take-up has been slow (the size limits and the temporary nature of the exemption create structural disincentives for investment) and what the regime’s limited participants have learned about the regulatory gaps that would need to be addressed for mainstream tokenized securities trading to function under EU law.

AMLA and the Crypto AML Architecture

The creation of the Anti-Money Laundering Authority — AMLA — as the EU’s centralised AML supervisor marks a significant shift in EU financial crime governance. For crypto, AMLA’s supervisory role over the largest and most cross-border CASPs creates a new layer of regulatory engagement that operates above national competent authorities.

CEPS has engaged with the design questions in AMLA’s operational architecture: how will AMLA select which CASPs to supervise directly? How will it coordinate with national competent authorities for firms that are large but primarily domestic? What methodology will it use for AML risk assessments in an asset class whose transaction patterns differ fundamentally from conventional banking? These are not questions that Commission communications or AMLA’s founding regulation fully answer, and CEPS’s technical analysis of them informs the regulatory guidance development process.

The CEPS Research Model

CEPS operates on a research model that combines academic rigour with policy proximity. Its researchers include former EU officials, former national competent authority staff, and academics with extensive consultancy experience in EU policy processes. This combination gives CEPS analysis both methodological credibility and operational relevance — it understands not only what EU rules say but how EU institutions work in practice.

For practitioners working in or with EU crypto markets, CEPS provides the implementation-level analysis that complements the macro-level frameworks from Bruegel and the official guidance from ESMA and national authorities. Its publications are detailed, technically demanding, and written for an audience that already understands EU regulatory architecture — not accessible introductions for newcomers but essential reading for those already operating in the EU crypto regulatory environment.

The institution’s Brussels location, insider networks, and sustained engagement with EU crypto regulation across its full development arc make CEPS one of the most valuable specialist resources for anyone working on the operational details of EU digital asset compliance.