Why a Swiss or Singapore firm must read MiCA

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Neither Switzerland nor Singapore is in the European Union, yet almost every digital-asset business established in Zug or Singapore has customers, counterparties or token holders in the Union. Regulation (EU) 2023/1114 on markets in crypto-assets, universally called MiCA, is the first full-scale licensing regime for crypto-asset services in a market of 450 million people. It applies to anyone who offers crypto-assets to the public in the Union, seeks their admission to trading on a Union platform, or provides crypto-asset services "within the Union". From 1 July 2026 it applies without transitional relief. A Swiss exchange that onboards German retail clients, a Singapore custodian with a Paris sales office and a Zug foundation that lists its token on a Dutch venue all face the question of whether MiCA reaches them.¹

The practical interest is twofold. First, MiCA defines what Swiss and Singapore firms cannot do from home. There is no third-country equivalence for crypto-asset service providers (CASPs), no passport for a Swiss or Singapore licence and a narrow reverse-solicitation exemption. Access to the Union market requires a Union entity. Second, MiCA has become a reference text. FINMA and MAS read it, the Basel Committee and the FSB cite it, and clients ask why Switzerland or Singapore does something differently. The Swiss and Singapore practitioner needs to know MiCA well enough to answer and well enough to decide when the Union subsidiary is worth its cost.

This chapter sets out MiCA's scope and architecture, the CASP licence, the stablecoin titles, the white-paper regime and the transitional periods that ended on 1 July 2026. It then turns to the questions that matter for a Swiss or Singapore base: the reverse-solicitation boundary, the EU subsidiary, Liechtenstein as the EEA bridge and DAC8 as the tax-reporting overlay. It closes with a three-way comparison of MiCA, Swiss law and Singapore law.

Notes

Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets, Art. 149: entry into force on the twentieth day after publication in the Official Journal, general application from 30 December 2024, Titles III and IV from 30 June 2024. Art. 143(3): existing providers may continue under national law until 1 July 2026 at the latest. ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.

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Dr Alexander Ressos, TEP

Of Counsel, KGP Legal LLC

I am Of Counsel with KGP Legal LLC in Singapore, where I work with a global client base of successful entrepreneurs and their families, independent asset managers, commodity trading houses and other commercial clients. I am a German and Swiss attorney-at-law, also admitted as a solicitor in England & Wales and in Hong Kong. I divide my time between Zug in Switzerland, Singapore and Hong Kong. Since 2017 I have advised international clients on more than 700 crypto and digital asset projects. I also have extensive experience in cross-border litigation and arbitration in Singapore, Hong Kong and other markets in South-East Asia and Greater China.

I operate across the key financial centres in South-East Asia, the Middle East and Switzerland, with a particular focus on asset protection, international tax and estate planning, as well as trusts, company administration and other fiduciary services. My philosophy is to serve as a trusted advisor working closely with my clients and to help them achieve their commercial objectives.

All Singapore law advice is provided through KGP Legal LLC, an established and duly licensed firm of Singapore advocates and solicitors.

KGP Legal LLC is a medium-sized law firm in Singapore that is capable of providing the full range of legal services and corporate administration work. Please contact me directly at [email protected] if you need any further information.

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SingaporeIQ is edited by Dr Alexander Ressos, an international business lawyer with more than 15 years of local experience in Singapore as a permanent resident, a Singapore registered foreign lawyer and managing partner of a Singapore foreign law practice. In addition to significant experience in cross-border investments and transactions, UHNWI private client work and sanctions/export controls, Dr Ressos has extensive experience in cross-border business and in crypto and digital-asset projects in Singapore, drawn from more than 700 projects since 2017.

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