As the financial industry undergoes rapid transformation, modernising core banking systems is no longer optional - it’s a necessity. With many banks still operating on legacy systems, some of which were implemented 30 to 40 years ago, these aging platforms, often heavily customised, struggle to keep pace with the demands of digital banking, real-time transactions, and seamless integration with fintech partners.
Several months following its publication, this paper examines ESMA’s 31 July opinion issued to National Competent Authorities (NCAs) and considers the impacts it is having on those seeking to operate within the parameters of Europe’s Markets in Crypto Assets Regulation (MiCAR). We assess how ESMA's guidance is reshaping the landscape for broker-dealer models, and how best execution requirements will require firms to make operational changes in a rapidly evolving regulatory environment.