ESMA puts reverse solicitation on its 2027 watch list: what investors need to know about exchanges without an EU licence

The European Securities and Markets Authority, ESMA, presented its work programme for 2027 on September 28, 2026. It contains a technical term that can have tangible consequences for European investors: reverse solicitation. It refers to the exemption under which a crypto exchange without an EU licence may serve European customers at all. ESMA has expressly put that exemption on its list of supervisory priorities for 2027. The most important qualification first, so that you read the news correctly: this is not a ban, and it does not take effect today. It is an announcement of what the supervisors intend to look at together over the coming year. That is precisely where its practical value lies for you. You have time to put your access, your withdrawal routes and your records in order calmly, while nothing has to happen under pressure. Reverse solicitation: the exemption in Article 61 of the MiCA regulation Reverse solicitation means this: a provider established outside the European Union may supply a crypto service in the EU only where the client has requested it at their own exclusive initiative. Article 61 of the regulation on markets in crypto-assets, MiCA for short, is therefore...