On 8 October 2026, ESMA set out its supervisory expectations: MiCA-authorised crypto service providers should not maintain or facilitate access to non-compliant stablecoins for EU clients, across all their services, from trading and order execution to transfers and custody. Where legacy positions remain, supervisors should require remediation "as soon as possible and no later than three (3) months" after publication, which puts the outer limit in early January 2027. Until then, only time-limited sell-only, conversion, transfer or withdrawal functions may continue, to wind positions down.

Behind the deadline sits a broader question: once you remove everything a European fund can no longer touch, how much liquidity is actually left? And how do you trade and price inside that perimeter?

We looked at 28 months of trades to find out.

How we measured it

• Data: trade-level data from 11 spot exchanges (Binance, Bitfinex, Bitstamp, Bybit, Coinbase, Crypto.com, Gate.io, Gemini, Kraken, KuCoin, OKX), July 2024 to September 2026.

• Pairs: BTC and ETH against fiat and stablecoins, stablecoins against fiat, and stablecoins against each other.

• Classification: USDC and EURC count as MiCA-compliant. USDT, DAI, USDS and FDUSD do not. Pairs that mix both groups, such as USDC/USDT, are left out of the comparison. EUR volumes are converted to USD at the monthly rate implied by USDC/EUR.

Two limits are worth stating upfront. Most exchanges run a single global order book, so a volume on Kraken or Coinbase is not a volume from European clients. And the study covers the main pairs, not the long tail of altcoins, where USDT is even more dominant.

On the euro side, MiCA worked

Start with the gateway between crypto and the euro: stablecoins traded directly against EUR.

In July 2024, compliant stablecoins accounted for 14% of that volume. USDT/EUR dominated. In September 2026, they accounted for 58%.

The shift came in one step, in early 2025, when major exchanges withdrew non-compliant stablecoins for their EEA clients (Gemini at the end of February, Binance at the end of March), following ESMA's guidance of January 2025. The compliant share jumped from 27% in February to 49% in March, peaked at 67% at the end of 2025, and has held between 55% and 60% since.

Total volume held up, between $6 and $10 billion a month. Liquidity did not leave the euro gateway. It moved from USDT to USDC.

On this narrow measure, the regulation did what it was designed to do.

Beyond the euro gateway, compliant stablecoins stay at one sixth

Widen the lens to every pair involving a stablecoin, and the picture changes completely.

Compliant stablecoins accounted for 16% of that volume in July 2024. In September 2026, they accounted for 17%. Two and a half years of MiCA, and the balance has barely moved. It even fell to 7% during the market peak of late 2024, when the extra volume went almost entirely to USDT.

In September 2026, on the pairs we studied:

• USDT: $176 billion

• USDC: $36 billion

• EURC: $238 million

Two points stand out.

The euro stablecoin is still marginal. EURC and EURI together traded around $290 million in September, about 2.5% of the volume on euro markets. European crypto liquidity runs on the euro itself and on USDC, not on euro stablecoins.

The accessible market is concentrated. Kraken and Coinbase handle about 80% of USDC/EUR volume, with Kraken alone at around 60%. A European fund's main route between crypto and the euro runs through two order books.

Put together: a European fund now has a working gateway to the euro, but behind it, it can reach roughly one sixth of the stablecoin market.

Operating inside a smaller market

What does this mean in practice for a fund that trades through EU-authorised providers? A few patterns follow directly from the data.

• USDC is the pivot. It is the only compliant stablecoin with real depth, against both the dollar and the euro. In practice, most flows between crypto and the euro will go through it.

• The euro itself beats euro stablecoins. With EURC at a few percent of euro volume, converting through EUR fiat pairs gives access to far deeper markets than going through a euro stablecoin.

• Concentration is an operational risk. When two order books carry most of the volume, an outage, a change of listing policy or a thin hour on one of them affects the whole route. Knowing which venues the fund actually depends on, and having a second route, is part of the setup.

• Timing matters more than it used to. Thinner markets mean that depth at the exact time of a trade, or of a valuation, can be very different from the daily average. This is especially true around month-end and year-end.

The January 2027 deadline adds one more constraint. Funds still holding non-compliant stablecoins with EU providers will be converting over the same few weeks, through the same few routes. Converting early, rather than in the last week, reduces exposure to that bottleneck.

Pricing with this many restrictions

The harder question is how to put a number in the NAV when much of the market is out of reach.

The principal market has to be accessible. Under IFRS 13 principles, the price should come from the principal market: the market with the greatest volume and level of activity that the fund can access. For many assets, the most liquid market today is quoted in USDT, on venues or pairs a European fund can no longer use. The most active market and the accessible market are no longer the same thing, and the pricing policy has to say which one it uses, and why.

An accessible market is often a thinner market. Thinner markets produce more fragile prices: stale last trades, small trades that move the price, sweeps a few minutes before the cut-off. We documented an extreme case at the September close, where a stablecoin's closing price on one exchange was set by a $1.90 trade from the morning (read the DAI case).

USDT-quoted assets need a conversion step. When the best price for an asset is quoted in USDT, turning it into EUR or USD requires a USDT rate, from a market the fund may not access either. That step has to be explicit, sourced and consistent from one close to the next.

Non-compliant stablecoins still need a price at year-end. Positions that must be converted in January still sit in the 31 December NAV. Their price has to come from somewhere, even if the markets the fund used to rely on are no longer available to it.

Conclusion

MiCA did what it set out to do at the gateway: the euro now trades mostly against a compliant stablecoin. But the market behind that gateway did not move. Compliant stablecoins still represent about one sixth of the volume, and the euro stablecoin barely registers.

For a European fund, that means a smaller, more concentrated and sometimes thinner market. Trading in it is manageable. Pricing in it requires choices that used to be implicit and now have to be written down: which market, which fallback, which conversion, which rules at the cut-off.

The January 2027 deadline makes those choices urgent. The 31 December close is the first one where they will be tested.

Find out our data through the Koinju API and our crypto pricing services.

For information only. This article does not constitute legal, accounting or investment advice, nor a Fair Value Assessment. Data: Koinju trade-level data, 11 spot exchanges, July 2024 to September 2026.

Regulatory references: ESMA opinion of 8 October 2026 on services related to non-MiCA-compliant ARTs and EMTs (ESMA75-113276571-1742); ESMA response to the MiCA review, 30 September 2026.

Sources

• ESMA, Opinion on the provision of crypto-asset services in relation to non-MiCA-compliant ARTs and EMTs, ESMA75-113276571-1742, 8 October 2026 (§ 21, 23-24, 27)

• ESMA, Response to the MiCA review, 30 September 2026

• ESMA and European Commission, Guidance on non-MiCA-compliant ARTs and EMTs, January 2025

• IFRS Foundation, IFRS 13 Fair Value Measurement