This note provides a high-level comparison of some of the key areas of MiCA and the HMT Proposals. It is relevant to participants in EU and UK cryptoasset markets, including service providers and issuers, as well as institutional and retail investors.

Readers should note that, since neither regime has been finalised yet, there may be further changes – this is particularly relevant on the HMT Proposals, which remain under consultation, with draft legislation and rules yet to be published.