Executive Summary Bearish (Market Access): ESMA’s aggressive stance on post-MiCA transitions removes all ambiguity by mandating an immediate halt to marketing and onboarding for unauthorised firms, effectively forcing an expensive, non-revenue-generating operational exit from the EU market. Bearish (Scalability): The Bank of England’s new regime for systemic stablecoins introduces artificial growth ceilings via strict issuance caps, restricting network effects and suppressing

1. Executive Summary: The Quantifiable “Cost of Legitimacy” and Market Consolidation This reporting period introduced several regulatory developments with substantial implications for CASP operational models and capital planning. The common theme is a rise in the measurable “Cost of Legitimacy,” as illustrated by the prudential requirements outlined in the Bank of England’s (BoE) consultation on systemic stablecoins. The proposal for a 40% unremunerated reserve requirement

Executive Summary Sarah Breeden, Deputy Governor for Financial Stability at the Bank of England, describes a multi-moneyverse' strategy...