Europe’s rulebook is fully in force and Washington’s CLARITY has stalled. Two days in Barcelona revealed that the work has shifted to supervision and to bridging borders where the rules stop.
By Can Koçlar and Matthew Rogers, for the Blockchain Legal Institute September 2026
The European Blockchain Convention opened in Barcelona on September 16, one day after the United States Senate refused to debate the CLARITY Act. The bill would set federal rules for US crypto markets. It got 49 votes and needed 60. Meanwhile, MiCA moves forward.
The two markets have reached the same moment from opposite directions. Europe has a complete rulebook and is finding out what it costs to operate under one. The United States has a stablecoin law and, for now, no law for the rest of what is still the world’s largest crypto market.
The conference panels and interviews pointed to three conclusions. First, Europe’s rules are not yet a competitive advantage, and may not become one unless remaining ambiguities are addressed and the framework is applied consistently in practice. Second, for licensed firms, the hard part is no longer getting the license but reporting to supervisors, which each country still handles its own way. Third, the rules stop at borders that the technology does not.
Two Europe-based leaders spoke with co-author Matthew Rogers on the sidelines of the convention. Jakob Mikkel Hansen is chief executive of the Nordic Blockchain Association . Sandro Knöpfel is global market structure lead at the Cardano Foundation.
Certainty without advantage
The CLARITY Act had passed the House in July 2025. It would split oversight of crypto markets between the Securities and Exchange Commission and the Commodity Futures Trading Commission. The Senate did not reject that design. It stalled over ethics rules on crypto holdings by public officials. That is some comfort to the bill’s supporters and none to crypto firms waiting for rules.
Knöpfel had built his remarks on stage that day around harmonization. Asked about the CLARITY vote, he said: “We were strongly hoping to see the CLARITY Act passing, because we need to have predictability and durability in the legislation to succeed with the industry and with the future integration of blockchain.”
American agencies have kept moving on their own. In December 2025, staff at the Securities and Exchange Commission issued a no-action letter, a written promise not to take enforcement action against a specific plan, to the Depository Trust Company, the central depository that holds securities for most of the US market. It allows the company to run a three-year pilot of blockchain-based versions of the securities it holds. The problem with such decisions, Knöpfel said, is their shelf life.
“No-action letters and agency decisions are good for the moment, and I believe the US is still one of the most progressive markets to push things forward,” he said. “But obviously this can always change as soon as we have a new administration. So it becomes very unpredictable for infrastructure providers, enterprises, financial services, whoever wants to build and deploy blockchain, to really know what they can do and to what extent.”
He did not conclude that Europe now holds a lead. Europe, he said, “has a legislative framework which gives a certain predictability or certainty, so one knows a bit what to do. But it does not necessarily mean that this is the big advantage which will now separate Europe from the US, because the capital and the drive for innovation are still bigger in the US.”
“While Europe has this more predictable legislation,” he added, “it needs to make sure that it does not fall behind when it comes to how it is being implemented.”
His example was stablecoins, digital tokens pegged to a currency such as the dollar or the euro. MiCA’s rules for stablecoin issuers took effect on June 30, 2024. By early 2025, major European exchanges had delisted stablecoins that did not comply, including Tether’s USDT, the largest in the world.
“The strict regulatory framework they established actually pushed the biggest stablecoin out of Europe,” Knöpfel said. “So it is still operated offshore, and Europe depends on the euro-denominated stablecoins. You will need to find the balance, and this is again the harmonization between legislation and the actual implications.”
Hansen read the Washington result differently. In the Nordic countries, the obstacle is indifference rather than hostility. The United States is “in some kind of way the market maker,” he said. “The better it goes in the US market, the better it goes in the European market.”
But what he values most about the bill, beyond the prospect of its adoption in the United States, is the attention it draws internationally. “If it was only one news mention and it got approved, versus it did not get approved and it was mentioned in the news every day, I would even say the latter would be the more positive, because that would create more awareness around it.” His point is not that failure in the United States would be preferable to passage, but that sustained debate around the bill can also have value for the European market by drawing the attention of European policymakers to the issues it raises.
From licensing to supervision
MiCA gave firms that were already operating under national rules time to get licensed. That time ran out on July 1, 2026, the latest date permitted under the law. Since then the question inside those firms has changed.
Hansen described MiCA as the moment Europe “finally wanted to unify something,” and said the work in the Nordic region has moved on from getting licensed. “It is mostly streamlined throughout the region, so it is more about: now the license period is done, now you have it, how do you actually report?”
Each country still interprets the rules differently and staffs its supervisory authority differently. “So there are of course different challenges in different regions,” he said, “but it is more or less the same things that need to be changed.”
That is where a common rulebook is weakest. The text is European, but reporting and supervision are run by national authorities. Tax, which MiCA does not cover, is worse. “There is different taxation in Denmark and different taxation in other countries, capital gains, capital losses,” Hansen said. “There is no consistency in how the Nordics are looking at this.”
The association has organized its work into three tracks in response: MiCA, personal taxation, and whether digital assets should get their own category or fit into existing savings and investment schemes.
Regulators face a familiar problem in the same phase. Rules written around one technology go out of date quickly. Rules that stay general leave firms unsure what compliance means.
Knöpfel’s experience of European consultations is that officials listen, and that the delay comes later. “From a political perspective they are a bit easier to access and to discuss with, which does not mean that they execute faster,” he said. “At the end of the day, the execution needs to kick in.”
Rules stop at the border
None of this stops at the EU’s border. Crypto businesses, protocols and infrastructure operate across countries. A firm active in several of them meets the same policy concerns expressed in different legal terms, with different supervisors and different compliance steps. The cost is less the number of rules than the joints between them, and the question of who is responsible when an activity crosses from one system into another.
“I want to break out of these silos we are building right now,” Knöpfel said. “I understand that we all have our economic preferences and want to strengthen our economies. But if you want to see this technology succeed, and if you want to increase efficiency through blockchain, we need to have a regulatory framework that does not stop at the border, but is as seamlessly interoperable as possible.”
He was not asking for identical laws. “Everywhere we have local law, so it will not just be adopted one to one,” he said. “But personally I would appreciate seeing the dialogue happening across regulators, from the US to Europe to Asia as well.”
His model came from the last financial crisis rather than from new technology. After 2008, banks discovered that nobody knew exactly who owed what to whom. The Financial Stability Board and the G20 answered with the legal entity identifier, a 20-character code that identifies every company in a financial transaction. It is run by the Global Legal Entity Identifier Foundation and overseen by several dozen public authorities.
“Now when we look into blockchain, everyone comes up with their own identity solution,” Knöpfel said. The Cardano Foundation built its identity tools on the verifiable legal entity identifier, a digital version of the same code that can be checked automatically. “So we suddenly have an identifier layer which is accepted globally and can be implemented in a blockchain solution.” Coordination, on that view, means reusing standards that already exist before inventing new ones.
The convention expected more than 6,000 people at Fira Barcelona Montjuïc, making it smaller than the biggest industry events. Knöpfel counted that in its favor. Regulators, traditional financial institutions, decentralized finance (DeFi) projects, and the blockchain networks themselves were all there. The format, he said, “gives you a unique platform to come together at a smaller table and have a productive conversation, rather than running through a conference, shaking hands and not having time for a follow-up.”
That is the practical case for the format. The problems described here are shared across institutions and countries, and they are easier to see when those institutions are in the same room.
Hansen’s hope is for a market where the line between decentralized and traditional finance stops mattering. “If we can figure out a good way for DeFi and traditional finance to merge,” he said, “then let’s forget the name and just call it finance.” The rules are some way behind that ambition. If Barcelona is any guide, the next phase will be spent closing the gap.
Can Koçlar is a legal and regulatory research contributor at the DARA – Digital Asset Regulatory Authority Foundation. Matthew Rogers is Strategic Director of DARA and co-founder of the Blockchain Legal Institute; he interviewed Jakob Mikkel Hansen and Sandro Knöpfel at the European Blockchain Convention in Barcelona on September 16–17, 2026.
