Crypto-Assets at the Regulatory Perimeter: Challenges, Data Gaps and the Standards Deficit

A summary for policymakers and supervisors of the European Central Bank’s July 2025 Occasional Paper (No. 394) on neo-conglomerates and EU regulatory perimeter challenges.

The crypto-asset sector has matured from a fringe experiment into a set of activities that increasingly resemble — and interconnect with — traditional banking and payments. In their July 2025 ECB Occasional Paper on “neo-conglomerates” and the EU regulatory perimeter, Phoebus Athanassiou, Stephanie Czák-Ludwig and Nico Di Gabriele offer a candid map of where supervision struggles to keep pace. This article summarises their findings for a policy audience. Their most important messages concern not any single firm, but the structural features of the sector: how value is unbundled and re-bundled across entities, how activities fall between regulatory regimes, and how supervisors are left with only a partial view.

 

Challenges from the sector and its players

Crypto-native firms rarely present themselves as banks, yet several now offer functionally bank-like services — lending, borrowing, staking rewards that behave like deposits, and payment rails embedded in wider “super-app” ecosystems. The paper documents how groups combine regulated and unregulated activities, hold multiple licences across jurisdictions, and rely on white-label partnerships and embedded distribution to reach customers. The result is a perimeter problem: activities such as crypto lending and staking sit largely outside the scope of the Markets in Crypto-Assets Regulation (MiCAR), even as they perform economic functions close to those the prudential framework was designed to contain. When a single group spans e-money, crypto, lending and payments across several Member States, no individual supervisor sees the whole.

 

Data gaps

The paper’s sharpest warning is about visibility. Supervisory registers, it notes, lack harmonised company identifiers, “making it difficult to consolidate group information.” More fundamentally, there is a “general absence of internationally accepted, harmonised, definitional solutions for innovative products, services and processes … whether for statistical or other classification purposes.” That definitional vacuum is not a technicality. Without common classifications for crypto lending, staking or DeFi activity, data cannot be collected consistently, compared across jurisdictions, or aggregated to reveal concentration and interconnectedness. Supervisors cannot measure what they cannot define — and in a sector where exposures migrate quickly across entities and borders, blind spots become systemic risks.

 

Policy recommendations

The ECB authors set out priorities that translate directly into a regulatory agenda. First, strengthen perimeter governance by harmonising the definitions of bank and bank-like activities, and bring hitherto-unregulated services such as crypto lending inside the perimeter — including clarifying how interest pass-through is treated and empowering the European Supervisory Authorities to intervene. Second, enhance oversight of multi-partner and white-label distribution models, including through more direct licensing. Third, introduce group-wide supervision for neo-conglomerates via an EU financial-holding structure. Fourth, improve cooperation, information-sharing and EU-wide reporting, supported by tools such as regulatory sandboxes and forward-looking risk assessments to detect emerging models early.

 

What the paper says about standards

For readers focused on standards, the paper is instructive on three levels. It leans on the existing international architecture — the Basel Committee’s Core Principles and its 2022 prudential standard for banks’ crypto-asset exposures (now flowing into EU law via CRR3/CRD VI), the Financial Stability Board’s 2023 high-level recommendations for crypto-asset activities, and the CPMI-IOSCO and IOSCO principles for financial market infrastructures and digital-asset markets. It then identifies where standards are missing: common definitional and classification standards, and harmonised identifiers, for the innovative products that now sit at the perimeter. And it flags the international limitation directly — “the absence of international standards or supervisory college arrangements tailored to neo-conglomerates make effective cross-border oversight challenging.” Notably, the paper does not engage with technical or messaging standards (such as ISO 20022) or token-level standards; its concern is definitional and prudential, not technical interoperability.

 

Takeaway for policymakers

The through-line is that standards — specifically shared definitions and identifiers — are the precondition for everything else. Perimeter harmonisation, consolidated supervision and reliable data all depend on first agreeing what a given crypto activity is. The EU can move ahead on harmonised definitions and reporting without waiting for global consensus, but durable oversight of cross-border crypto groups will ultimately require standard-setting bodies to close the international gap. For a sector defined by speed and structural creativity, the supervisory response begins, unglamorously, with a common vocabulary.

 

Reference

Athanassiou, P., Czák-Ludwig, S. and Di Gabriele, N., “Neo-conglomerates and EU regulatory perimeter challenges – state of play and evaluation of policy options,” ECB Occasional Paper Series No. 394.