Peter Märkl, General Counsel at Swiss crypto exchange Bitcoin Suisse, has pointed out a lack of clarity in the stablecoin regulatory frameworks of both the European Union and Switzerland.
Märkl emphasized that “there’s a lot to be done” regarding the classification and regulation of stablecoins under the EU’s Markets in Crypto-Assets Regulation (MiCA).
While MiCA offers what he called “a comprehensive, harmonized regulatory framework” for the issuance, offering, and custody of stablecoins, Märkl noted that crypto-assets and their use cases continue to evolve rapidly. As a result, classification “remains dynamic and can, in certain cases, shift over time.”
He also pointed out that MiCA’s structure can place non-EU players at a competitive disadvantage.
“Foreign stablecoin issuers need to seriously consider a license under MiCA as recent supervisory actions in Germany point to a strict enforcement of the rules.”
Regarding Switzerland’s regulatory approach, Peter Märkl criticized the country’s rules as being unfriendly toward stablecoin issuers. He pointed out that Swiss regulators place the burden of Know Your Customer (KYC) compliance on the issuers themselves, effectively requiring them to identify individual token holders—something he described as “unreasonable.”
Reflecting on the broader regulatory landscape, Märkl acknowledged that while Switzerland’s DLT Act—introduced four years ago—was “a great legislative platform,” significant gaps remain. He stressed the importance of prioritizing stablecoin regulation and establishing “a set of rules that is comfortable for the players.”
“There is a legislative process underway,” he added, “but the outcome still needs to be evaluated.”
Bitcoin Suisse’s EU ambitions
Märkl also noted that Bitcoin Suisse plans to use its five-year-old registration as a Crypto-Asset Service Provider in Liechtenstein as a foundation to pursue a full MiCA license.
“In terms of Bitcoin Suisse, we have run a subsidiary in Liechtenstein for five years, which is nationally registered under the TV2 law. It’s a registered CASP, and it would be a natural choice to extend this to a MiCA license.”
Middle East, UK and US also in the crosshairs
Bitcoin Suisse is also setting its sights on international expansion beyond Europe. The company secured in-principle approval from the Abu Dhabi Global Market (ADGM) in May, and General Counsel Peter Märkl revealed that CEO Andrej Majcen relocated to Abu Dhabi around 18 months ago. According to Märkl, the firm sees “tremendous attraction” in the Middle Eastern market.
In addition, Bitcoin Suisse is exploring potential opportunities in both the United Kingdom and the United States. However, Märkl noted that any final decisions will depend on how regulatory landscapes evolve in those regions.
