Imagine a future where any asset - whether real estate, art, or equities - is accessible to anyone, breaking barriers like geography, wealth, and institutional gatekeeping. Tokenisation is making this possible by converting assets into digital tokens that are easily transferable and universally accessible.

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.