MiCA gave crypto a passport, but customers still face borders

For months, Hungarian crypto customers waited for a return to normal trading, but the answer depended on which app they used. Bitvavo announced that trading and euro deposits were returning for Hungarian customers, with new registrations reopening on Sept. 7. When checked on Nov. 13, Revolut's Hungarian help page still described the shutdown of its crypto services and account closures tied to a December 2025 deadline.

Support pages can outlive the restrictions they describe, so the notices show what each company published, while actual access would require an account or transaction test to verify. The European Union spent years building a common framework so authorized crypto companies could expand without collecting a separate license in every country. MiCA gives authorized crypto companies what's known as a passport.

Under Article 59(7), a company can offer its approved services elsewhere in the EU without opening a local office. It tells its home regulator where it intends to operate and which services it plans to offer. Under Article 65, it can start once it receives confirmation that the information has been sent to the relevant authorities, or no later than 15 days after submitting it.

Hungary's extra rules blocked the passport

Revolut's crypto subsidiary received MiCA authorization in Cyprus in October 2025, and France's financial regulator lists it as authorized to offer crypto services in France under that same framework. The passport lets providers serve new markets and decide where to offer each approved service. Hungary complicated that process in 2025 when amendments to its crypto legislation added an extra requirement to validate crypto conversions, backed by criminal penalties.

Companies already authorized under MiCA now had an additional Hungarian requirement to meet. Revolut's instructions told customers to sell their crypto by Dec. 18, 2025, and said it would sell any remaining holdings automatically and close their crypto accounts. On Jan. 30, the European Commission opened an infringement procedure, arguing that MiCA gave Hungary no basis for the extra authorization regime.

The Commission acknowledged Hungary's interest in preventing money laundering and argued that any measures it adopted had to comply with EU law. Hungary repealed the requirement before a court ruled on the dispute. Act XXXVIII of 2026 took effect on Aug. 7, and its official explanatory memorandum acknowledged that the requirement was incompatible with EU crypto regulation.

MiCA's maximum transitional period had already ended on July 1, 2026. The repeal gave companies room to reopen services, as Bitvavo announced it would. Even then, its general eligibility page, updated on Nov. 4, omitted Hungary from its list of supported countries. Its dedicated reopening notice and country payment page both listed services for Hungarian customers.

The dedicated notice better explains what Bitvavo said it would do in Hungary, although someone trying to work out whether they could sign up could read two pages from the same exchange and come away with different answers.

Borders move to payment menus and legal entities

Once you have an account, the differences between countries often show up when you try to add money. Coinbase's European payment guide lists Easy Bank Transfer for cash deposits in the Netherlands, Finland, France, Germany, and Ireland. It lists card deposits in the Netherlands, Italy, and Spain, while Polish customers can use BLIK to buy crypto directly.

Buying crypto and depositing cash are separate entries in the guide, so when Germany is missing from the card deposit list, that tells you about funding an account. To see if you can buy crypto with a card, you'd check the purchase column. Kraken's support documentation gives another example. Dutch residents can use iDEAL to deposit euros on Kraken, and withdrawals require a different method.

These differences can come down to how an exchange has arranged to move money between a customer's bank and its platform. Under Article 70(4), an exchange can handle associated payment services itself or use a partner, provided whoever handles the payments has the required authorization. The exchange must tell customers who provides the service and what terms apply.

MiCA imposes separate duties on how companies give customers access to crypto services. Article 76 requires trading platforms to use objective, non-discriminatory access rules and proportionate participation requirements. Their fees must also be transparent, fair, and non-discriminatory. Article 77 applies when a provider buys or sells crypto directly with customers using its own capital.

It requires the provider to publish a non-discriminatory policy explaining whom it serves and what conditions customers have to meet. Guidance published by the European Securities and Markets Authority explains that the provider must fill an order once the customer meets the published conditions and the order becomes final.

To assess whether a provider has breached those duties, you'd need to compare customers asking for the same regulated service from the same legal entity, taking into account eligibility and any required compliance checks. Coinbase's card deposit options in Germany and Italy and Kraken's rules for iDEAL tell you which payment methods are available. They give you only part of the information you'd need to make that comparison.

Rejecting an otherwise reachable EU bank account solely because its IBAN comes from another member state can amount to IBAN discrimination under SEPA rules. You'd need evidence that a provider refused an eligible account because of its IBAN. The public guides tell customers which local payment methods each exchange supports.

One app, several rulebooks

When you move between trading, payments, and rewards in the same app, you may be dealing with a different company on each screen. Kraken's European Economic Area terms, effective Oct. 14, put its core crypto services under an Irish MiCA-authorized entity. Another Irish company handles electronic money, and a Cypriot investment firm provides derivatives and xStocks. The agreement also lists separate terms for staking and margin trading.

Coinbase's European migration notice describes a similar split. Coinbase Luxembourg took over crypto services under its MiCA authorization, while Coinbase Ireland continued to provide electronic money services. You can see both balances in the same account even though one company is responsible for the cash balance and another provides the crypto services. Each license covers the company that holds it and the activities that company has been authorized to carry out.

Both platforms assign crypto and electronic money services to separate legal companies. Staking shows how protections can depend on what a provider does with your assets. MiCA has no separate staking regime, but if a provider holds your crypto or private keys while staking on your behalf, that custody activity is subject to MiCA's authorization and custody requirements.

The European Commission explained how this works in guidance published through ESMA. ESMA has also warned that when a regulated company offers other products alongside its licensed services, customers can assume those products come with the same protections. Under Article 66, companies must explain the services they offer accurately, with fair, understandable information that doesn't mislead customers.

In Revolut's Hungarian case, readers of the old notice are left wondering whether the halt is still in effect and, if so, what's keeping it in place now that Hungary has repealed the validation rule. To assess the notice under MiCA, a regulator would need to determine what Revolut currently offers in Hungary and why any restrictions remain in place.

Parts of the European market already work the same way across borders. Kraken's European restrictions page groups customers across the European Economic Area together for certain restrictions on assets and rewards. Hungarian customers trying to work out whether they can trade again have a different problem. The law that prompted the shutdown is gone, but the information they need is specific to the exchange: whether it will accept their account, how they can fund it, and which company will handle their assets once they do.