ESMA Supervisory Opinion on Stablecoins: Exit Routes and Market Connections

1. Ending trading and returning clients’ assets

On 8 October 2026, the European Securities and Markets Authority (ESMA) addressed national authorities on all Markets in Crypto-Assets Regulation (MiCA) crypto-asset services involving non-compliant asset-referenced tokens (ARTs) or electronic-money tokens (EMTs), retaining offer/admission interpretations. Subject to exemptions/transitions, crypto-asset service providers (CASPs) should promptly remediate legacy exposures within three months of publication. Temporary, closely supervised exits/safekeeping may protect existing holdings only, without new acquisitions or continued market availability.[1]

When stablecoin services are being reduced, considerable work can remain between a token disappearing from the trading screen and clients receiving their assets elsewhere. Someone with an open sell order, someone who has not registered a destination and someone awaiting approval from a corporate finance team may see the same balance but have different actions available. Assessing a provider’s response requires a fixed set of affected clients and assets, followed by a record of what has actually been completed.

Suppose a business has deposited tokens intended to pay a supplier. Even if their displayed value is preserved, the business cannot use those funds unless it can convert them into an asset its supplier accepts. If the tokens reach a receiving account, however, the original provider’s balance can fall without the business losing its assets. Counting the end of trading, the return of assets and the disposal of holdings as the same outcome misrepresents how far the migration has progressed.

Count completed steps

This distinction is also the starting point for assessing effects on European markets. Large price movements are only one possible sign of a burden. If balance reconciliation, identification of the contracting entity, renewed withdrawal requests and explanations to counterparties take time, costs are distributed between providers and clients. Looking only at market-wide prices can obscure burdens concentrated among a few clients, or the problem of processing costs weighing more heavily on smaller balances.

SG Group approaches the issue in three stages. First, identify the services being reduced and the affected clients. Second, establish whose accounts change through a sale, redemption or transfer. Third, compare the costs of completing that movement and the dependencies that remain afterwards. This sequence evaluates the response through both the assets clients can receive and their connection to markets, instead of relying solely on falling trading volumes.

2. The scope of the new supervisory opinion

Translating this development into operations requires more than a single response date for the whole company. Staff changing order acceptance, those handling unsettled orders and those returning assets may hold different information. What is needed is a map connecting the contracting legal entity, its clients and the functions it supplies, using consistent units throughout.

Published policies and companies’ completion reports

A company’s policy announcement does not mean the same operation immediately finishes in every account. Whether clients received the notice, whether requests remain outstanding and whether the returned assets are usable at the destination are separate outcomes. Connecting a regulatory response to market data therefore requires an understanding of these intermediate steps, rather than simply comparing an announcement date with balances.

The later sections assume a provider and a token whose services are being reduced, then examine the conditions under which client exits can progress. They do not assume that any named firm has already stopped trading, that clients have incurred losses or that funds have left the EU. Assessing a particular company requires its notices by function and the processing results for the relevant accounts.

3. Comparison with the 2025 statement

ESMA’s 17 January 2025 statement set end-January acquisition restrictions and first-quarter compliance for offer/admission-related services, with a sell-only transition. Mere custody and transfers could continue.[2]

The European Commission’s Q&A 2404 treats listing non-compliant ARTs/EMTs as seeking admission to trading, assessing other services individually. It explains existing law without adding obligations.[5]

Reusing only a list of previously discontinued functions when reviewing earlier responses can miss how clients use an account now. For example, a client who stopped trading may still use that account to receive assets. Conversely, a displayed balance could consist entirely of assets awaiting return, with no new use occurring. A function’s name on a screen cannot be mapped directly to changes in actual balances.

Move from company-level comparisons to individual functions

A useful comparison is more detailed than a division between companies that “responded” and those that did not. Listing the affected clients, requests still accepted, completed movements and unresolved exceptions reveals how identically named functions can serve different purposes. To learn from an earlier transition, records showing which requests remained until the end and what resolved them are more useful than preserving the old interface alone.

4. Issuers, service providers and supervisors

MiCA classifies tokens seeking stable value: EMTs reference one official currency; non-EMT ARTs reference values or rights. Offers and admissions generally require issuer authorisation, with exceptions. CASPs must protect assets and clients’ best interests. States designate authorities; the European Banking Authority (EBA) supervises significant ART issuers and specified significant-EMT obligations of electronic-money institutions.[3]

Article 29(1)(a) of ESMA’s founding regulation provides for opinions to authorities promoting supervisory consistency. Issuing an opinion differs from amending legislation.[4]

One brand can involve several counterparties

Users may see a single brand, but the token issuer, account provider and trading counterparty need not be the same entity. If the account provider changes its services, the relationship with the issuer does not automatically move to another company. Conversely, information about the issuer alone does not establish the steps required to receive assets held in an account.

When updating a counterparty list, a business should therefore focus on contracts and account names rather than the name displayed on screen. If there are several contacts, distinguish who verifies balances, who quotes a conversion price and who proves final receipt. Directing every question to the issuer may leave a process stalled at the account provider unresolved.

Understanding custody arrangements and assessing a particular token’s compliance are also separate tasks. The guide to exchange, custody and withdrawal dependencies helps with the former. For this market analysis, the contracting entity is fixed before following movements in the client balances it handles.

5. SG Group’s view: the work beyond the trading screen

Consider a company that has decided to reduce its services. The scope is one token held by clients contracted with that company. First, identify the relevant accounts and separate balances from unsettled orders. Without that distinction, freely transferable assets and assets still tied to execution or cancellation can appear within the same number. Completion rates cannot meaningfully be compared if the starting ledgers differ.

Next, list the work required for each route clients choose. A transfer to another destination requires the receiving account and supported network as well as the sender. A sale adds order acceptance and confirmation of the execution price. Redemption through the issuer involves a channel connected to that process and the necessary checks. Combining these routes under the single word “withdrawal” makes it difficult to explain where a delay occurred.

Map what is being stopped and what must be finished

The process map needs a place to send rejected requests back, as well as arrows for successful cases. If destination information is wrong, does the request return to the acceptance stage, or are the client’s assets first released from the pending instruction? Accepting another instruction before a cancellation is processed risks attaching two requests to the same assets. This describes a design difference that can be examined in migration plans, not an incident at a particular company.

Changes to the trading screen are visible to users. Final receipt and reconciliation may nevertheless finish outside it. SG Group therefore assesses progress through the share of requests that can be traced in a continuous record from the affected account to the destination, rather than through the number of buttons removed. Comparisons become more reliable when exceptions can be traced back to the same starting population, instead of counting only clients with simpler processes first.

6. A falling account balance can coexist with rising client holdings

Measuring a migration requires a defined boundary. If a client holds the same token with several providers, a decline at one company does not reveal the client’s total holdings. A move from the original account to another changes custody location, but generally leaves the quantity exposed to price changes and issuer-related economic effects intact.

Suppose the client also trades at the destination. Their total quantity could even be higher than before when the original account reaches zero. This does not mean the departing provider’s ledger is wrong. Completion of the company’s process and changes in the client’s asset allocation are different questions. This difference in denominators matters to the economic analysis even before a detailed supervisory assessment is attempted.

Reconcile ownership, quantity and value separately

A corporate group can contain several legal entities under one brand. Even if the same employee manages them, moving one entity’s balance to another cannot simply be recorded as movement between accounts of the same owner. If ownership of assets or claims changes within the group, documentation must establish that change. A quantity appearing on the recipient’s screen does not necessarily complete the original entity’s accounting.

Quantities and valuations should also be followed separately. An unchanged quantity with a different value in the display currency calls for a different explanation from an actual reduction in quantity. If fees are assumed to be deducted in the token itself, separate those fees from the quantity received. Reconciling the opening quantity, movements, quantities spent on fees and remaining quantity avoids treating every small difference as a loss or missing asset.

If a public disclosure contains only company-level balances, the questions it can answer remain company-level questions. Different aggregates are needed to extend a conclusion to clients’ worldwide assets or the issuer’s total outstanding balance. Fixing the denominator preserves the precise scope of what can be explained; it is not a device for making the impact look larger or smaller.

7. The requests left near the end of an exit

Migration looks straightforward if every client is assumed to be able to provide a destination immediately. Remove that assumption and work emerges that cannot be completed merely by reducing the number of affected accounts. An account with outdated contact details, a changed corporate approver or an order awaiting cancellation can hold assets while the next instruction remains unconfirmed. Excluding these accounts from the totals can produce a high completion rate based only on easy requests.

Small balances present distinct problems. If the recipient imposes a minimum quantity or fixed processing costs are large relative to the balance, the route used by other clients may be impractical. That does not justify simply erasing the balance. The relevant questions are which costs fall on whom and what conditions accompany the alternatives available to the client.

The types of exception reveal the remaining work

Suppose outstanding requests are divided into “awaiting client response,” “awaiting destination verification,” “awaiting order processing” and “awaiting ledger reconciliation.” Some can be resolved with additional staff; others require an outside response. The remedy differs even though both are incomplete. Combining them into one backlog number obscures whether the company should add staff, improve its instructions or provide another receiving route.

The number of times a request is returned also matters. A process that identifies missing documents once creates a different client burden from one that adds another check at each stage, even if the eventual checks are identical. When corporate staff must repeatedly seek renewed approval, the predictability of instructions affects costs alongside elapsed time. Reducing the checks required and making their sequence easier to understand are distinguishable improvements.

Near the end of an exit, the types of request still open can be more informative than the total processed. If large accounts finish first, progress can look strong by value while numerous small accounts remain. Keeping the same client cohort and examining both counts and values shows where the final burden is concentrated.

8. Who takes on the costs and responsibilities?

A company announcing a service reduction may not possess every function needed for the migration. If the party quoting a sale price, the party holding the received assets and the staff updating a business’s books are different, the process involves several decisions. Users may see a single fee, yet the underlying work may not be something one company can complete alone.

Assessing cost transfers also requires a precise reading of “free transfer.” Waiving only the sender’s fee and covering conversion costs after receipt produce different final asset values for the client. If the recipient charges separately, the word “free” does not allow users to compare total costs. The starting point is the contractual scope of the offer, without guessing actual charges.

Who gains, and who takes on the work?

The receiving company has an opportunity to establish a new client relationship. Incoming balances generate future revenue only if the client continues using its services, however. Receiving a transfer does not by itself establish higher profits. Large volumes of checks and inquiries may arrive first, and recovering those costs from small accounts may be difficult. Client acquisition and profitability are separate measures.

The party quoting prices also acquires both a trading opportunity and an inventory burden. Suppose orders are concentrated in one direction over a short period. Counterparties able to adjust their holdings after taking those orders are better placed to offer stable terms. Conversely, directing clients to one price provider may simplify administration for a company seeking quick exits while reducing bargaining room. A simpler process need not be cheaper.

Comparing cost allocation also requires asking who controls the cause of the cost. Costs arising from contracts or routes the client cannot change call for a different explanation from costs caused by an additional conversion the client chooses. Clarifying that allocation makes it easier to assess migration outcomes, including inquiries and disputes that remain after the exit.

9. Sales, redemptions and transfers change different accounts

A sale exchanges the seller’s tokens for the buyer’s consideration. Once completed, the seller holds fewer tokens, but those tokens pass to the buyer. Achieving a client’s exit does not by itself reduce the issuer’s liabilities. Market-wide analysis should therefore avoid adding tokens relinquished by a seller to a decline in outstanding issuance as if they were the same measure.

Under MiCA, EMT holders have issuer claims, par redemption and no redemption fees, without prejudice to Article 46.[3] These provisions should be distinguished from the channels and procedures a particular user actually employs. Selling to a third party in the market and receiving payment from the issuer involve different contacts and different evidence of completion. Par value alone does not determine the market execution price or the cost of conversion into another currency.

A transfer changes the place of custody

A transfer moves tokens from the original custody location to a destination. Assuming the owner remains the same, the service provider’s managed balance falls while the owner continues holding the assets. Their economic usability depends on whether the destination supports the same token in a usable form and can link its arrival record to the client’s account. Counting a sending record as a completed exit omits this receiving-side work.

An exchange into a different token can change both custody location and asset type. Combining that transaction with a simple transfer in the same category can hide price differences and dependence on a new issuer. If a company replaces balances managed in the original token with another, an apparent one-for-one quantity does not establish an identical reference currency, contractual counterparty or eventual conversion channel.

For comparison, first align the starting asset and the final asset received. If one route ends in bank-account cash and another in a token, intermediate fees alone cannot establish which is preferable. Where the final purpose is the same, compare the routes including any additional exchanges and movements required. This connects with the foundations in stablecoin reserves and redemption conditions.

Distinguishing the three routes also improves client communication. “Returned” should not conflate tokens being sent, sale proceeds being paid and a redemption request being accepted. Identifying whether a case is at the request, execution or receipt stage narrows down whom to contact and what further documentation is needed.

10. Interpreting falling exchange balances

To follow the same client cohort, call the provider reducing its services A and another destination B. Assume the client’s tokens at A are moved unchanged to B, with fees paid separately. A manages fewer tokens and B manages more. This movement alone leaves both the client’s quantity and the total quantity of tokens outstanding against the issuer unchanged. It is a transfer away from one company, not evidence of money leaving the token as a whole.

Now assume a completed redemption: the token returns to the issuer, the corresponding liability is extinguished and consideration is paid to the client. Both the form of the client’s asset and the issuer’s liability change. The entire process cannot be counted as complete at the application or sending stage. Nor should the contractual extinguishment of a liability always be equated with a network operation such as burning tokens.

Do not count the same movement twice

The quantity moving from A to B can be observed as an outflow at A and an inflow at B, but adding them would double the client’s migration quantity. Adding an intermediate custodian creates further transmission records for the same assets. More processing events therefore need not mean more clients or assets have exited.

When using public transfer data, fix the unit being counted. Transmission events, clients, token quantities and converted monetary values reveal different changes. A small test transfer followed by the main transfer increases the event count while the client remains one person. An internal rearrangement of custody locations is another movement distinct from a client exit.

A further pitfall is a changing population. A completion rate following only the starting clients is not comparable with balance changes across all accounts, including clients subsequently arriving from another company. Separating a fixed-cohort table from a company-wide table can explain how a specific migration progresses while the provider’s total balances rise.

11. Compare price stability with exit completion

When affected clients sell at the same time, the price effect depends on the availability of counterparties willing to take their orders. An unchanged best price on screen does not mean the entire affected balance can be sold at that price. A small order may leave the price unchanged while a larger sale consumes orders at progressively less favourable prices. Execution conditions must be compared over the same quantity and period.

Conversely, ample price providers do not make a route usable if destination verification is unfinished. Good execution prices for the clients able to trade do not establish smooth exits for everyone else. Price assessments using those who could trade as the denominator need to be read alongside processing assessments covering everyone in the initial population.

Unfinished clients disappear from some averages

An average processing time calculated only from completed requests excludes those still waiting. The more quickly short requests finish, the better that average can look. Showing the age and number of outstanding requests separately gives a closer account of the exit. As with prices, identifying which clients enter the observation is necessary to distinguish improvement from selection.

The reverse inference is also unsound: a few delayed cases do not establish market-wide dysfunction. Delays spread widely through the affected cohort have a different economic meaning from delays concentrated in individual cases with missing information. Breaking the population down by business size, balance size and exit route helps identify the conditions under which costs arise.

The foundations in quoted prices, order books and execution help interpret sale terms. The purpose is to distinguish a displayed price from the quantity actually executable at it, not to equate the regulatory arrangements for equities and crypto-assets.

12. Cross-border price differences and client movements

When the same token trades in several places, counterparties able to buy in the cheaper market and sell in the dearer one can help narrow price differences. For these exits, however, access to both markets is a condition. A higher price at an inaccessible venue is not an available sale price for the affected client. Large global volume alone does not establish the options of clients exiting a particular contracting entity.

Comparison should therefore fix who can trade at each price, rather than merely line up prices by region. Different account eligibility, received assets, required conversions or settlement counterparties can embed different costs in the two prices. A migration destination becomes a comparable, available alternative only after its ability to serve the same client cohort has been established.

A currency label does not establish where funds go

Suppose a client leaves a dollar-referencing token and receives a dollar bank deposit. The asset vehicle changes, but the choice to hold value in dollars continues. If the client exchanges into another currency, the currency composition changes too. Calling both cases a move away from the dollar obscures the actual change. Changes in European intermediation routes do not immediately establish the direction of global dollar demand.

Businesses may also face a difference between the currency a supplier requires and the asset form they find easy to manage. Comparing destinations should include whether another currency exchange is needed after receipt and when its terms will be fixed. For this operation, identifying which currency exposure is borne between starting the exit and having spendable funds is more directly relevant than predicting exchange-rate direction.

This connects with foreign-currency assets and FX conversion. Using a consistent accounting currency while recording price differences, conversion effects and fees separately helps identify the causes of migration costs. It also avoids assigning market-wide currency movements solely to one supervisory opinion.

Assessing the international scale requires knowing which routes the affected clients’ assets take and what they are used for afterwards. Clients keeping the same token elsewhere leave different global trading relationships from clients switching assets, even if the original region’s volume declines by the same amount.

13. Migration costs absent from the fee schedule

Comparing two exit routes requires the same endpoint: delivering the same asset to the same recipient. Then separate quoted fees, execution-price differences and network charges. If one route delivers only an intermediate token while the other reaches a bank account, the initially displayed amounts are not comparable. A route that looks shorter may leave the client with work to do later.

Business costs include human work. Registering receiving accounts, obtaining internal approval, reconciling balances and preserving audit trails can make the total cost substantial even when network fees are small. If the same process must be repeated across many accounts, whether fixed checks can be completed once may matter more to the burden than the quantity of assets.

Record who could choose the cost

Before consolidating costs into a total, record their causes and who bears them. The expense of connecting to a destination chosen by the provider, the cost of a different currency requested by the client and additional work caused by the recipient’s specifications should remain distinguishable for later explanation. Comparing totals without their causes also hides what could be reduced in a future migration.

Funds held up in the process create different costs when additional financing is actually needed and when spare cash can absorb the delay. Applying a uniform interest rate to unavailable balances and calling the result a loss ignores the business’s funding position. If bridging payments required borrowing, establish its duration and terms. If no borrowing occurred, distinguish estimated opportunity cost from cash expenditure.

For small personal accounts, the same fixed fee represents a larger share of the balance. This helps explain how migration can look smooth by value while burdens remain among numerous small holders. Comparisons by balance size can reveal differences hidden in the total. Their actual size must nevertheless be established from charges and the routes used.

14. Returning assets that a business can use for payments

In a corporate account, the person receiving assets may differ from the person using them for payments. Even after the migration team confirms receipt, those assets may not be usable funds for the finance department if internal approval to pay a supplier is unfinished. Final reconciliation must connect the goal of completing the account migration with the business’s goal of paying on schedule.

Consider a business receiving another asset after converting the affected token. Its invoice may be denominated in the original currency, while the receiving account belongs to a new contracting entity. The business then updates not just the balance but the asset’s legal owner, the accounting currency and the payment channel. The work extends beyond changing a destination address and may require several teams within the same company.

Duplicate payments through parallel routes

If another source of funds pays the bill before migration finishes, establish what happens if the original request completes later. Execution of both the substitute transfer and the original payment instruction creates new work to arrange a refund with the recipient. Linking asset returns to invoice reconciliation avoids confusing the return of funds with the settlement of an unpaid invoice.

At month-end or period-end, records tracking assets already sent but not yet confirmed as received also matter. Applicable accounting standards and contracts require their own assessment. At a minimum, linking the request identifier, asset, quantity, counterparty and status reduces discussion based on different lists held by different staff. If reconciliation lags behind operational progress, further checking is needed for reporting.

Corporate effects may emerge through these additional operating costs. They do not apply equally to every business. A company that does not use affected accounts, or holds assets without using them for payments, faces different work. Before extending the argument to worsening cash flow across international businesses, establish which companies depend on the assets at which operational stage.

15. More destinations do not necessarily diversify dependencies

Several receiving destinations provide more options if one route becomes unavailable. But if they depend on the same issuer, conversion counterparty or receiving bank, conditions that affect them all at once remain. Increasing the number of destination names and increasing the independent routes that the affected clients can actually use require separate assessment.

Suppose two receiving services convert the token into another asset through the same third party. If that party has limited processing capacity, dividing users between two services does not remove congestion at the conversion stage. There may be more client-facing contacts while the capacity to deliver final assets remains shared. This is why analysis should look beyond the visible contracts to where the processes converge.

What to check after assets reach the destination

Judging exit completion solely by the original company’s balance makes it difficult to evaluate new dependencies at the destination. Did the client receive the same token or another asset? Can the assets be moved onwards, or is their intended use confined to trading there? Comparing required counterparties before and after migration specifies which risks have been reduced and which remain.

Adding routes also costs money and work. More account openings, administrator permissions, reconciliations and contacts make users’ operations more complex. To compare the benefit of an independent route with the burden of managing more counterparties, first specify the disruption that diversification is intended to address. Adding more parties of every kind does not necessarily make this migration smoother.

The relevant outcome is whether the affected client can complete receipt without relying on one party, not the number of services registered. Even if an alternative route exists, very few eligible clients may be able to use it. That does not establish the same improvement for everyone. Checking availability within client groups reveals the difference between nominal and practical options.

16. Testing the case for a limited market burden

The strongest counterargument is that affected balances and users are already few, so service changes have little market-wide impact. This is entirely plausible. Assessing it requires comparing the size of the affected client cohort with the destinations’ capacity to receive it. Connecting the event directly to international financial instability without establishing the affected scale would be a leap.

A second counterargument is that users have already prepared, leaving little additional migration to complete. Outstanding requests and remaining quantities then matter more than the total account count. Even if most work is done, however, the final cost may be material if the remainder consists of difficult accounts. Examining the nature of outstanding cases alongside the progress percentage makes this argument more testable.

What would abundant alternatives look like?

A third counterargument is that plentiful alternatives allow competition to contain client costs. If this explanation is strong, the same affected clients should have several executable routes whose costs and receipt conditions can be compared. What matters is the number and terms of routes those clients can actually use, rather than the number advertised. If more receiving services all converge on one conversion counterparty, the role of competition requires separate examination.

Conversely, a few accounts of slow processing do not prove a large-scale burden. Their share of the total population and the stages where exceptions cluster must be established. Individual complaints can help identify causes, but cannot simply be expanded into a market-wide estimate. Aggregate evidence and specific examples should be combined to examine both burdens concealed by averages and impressions exaggerated by exceptions.

Stating in advance the conditions under which these counterarguments would be accepted strengthens the assessment. Small affected balances, usable alternatives and few unfinished accounts would make an outcome confined mainly to companies’ operational adjustments more plausible. Opposite findings would justify deeper investigation of the path to receipt as well as prices.

17. Compare benefits and burdens within the same client cohort

Those benefiting from a migration need not be those paying its costs. Streamlining a company’s supported assets may simplify future administration, while existing clients must search for a destination. Even if future users find services easier to compare, existing clients’ migration costs do not disappear. The two groups should be considered over separate periods and within separate client populations.

A useful way to test this is to fix the affected accounts at the outset and follow their receipts. Adding newly acquired clients halfway through mixes users lost in migration with users attracted by a new product. Growth in the company’s total accounts does not establish a light burden on the original clients. Separating acquisition results from existing-account exit results creates records useful for both assessments.

Balance size alone does not establish smooth progress

If large accounts finish first, progress by value looks rapid. Problems among small accounts—such as missed communications or quantities below a destination’s minimum—may barely register in the total. Conversely, focusing only on counts can miss how a large unfinished balance affects a business’s payments. Comparisons should identify whether the objective is to improve quantities, values or client counts.

If the provider absorbs costs, their eventual destination still matters. Zero fees on an affected account do not mean that additional work is costless. Whether the company absorbs it through profits or reflects it in other charges requires evidence from the actual fee structure and results. No charge to the client and no migration cost should not be used interchangeably.

Clients’ scope to choose also has value. Receiving the same quantity can leave different work depending on whether it reaches the desired asset and account or the only available route requires further processing. When evaluating options, the routes executable by the original clients and their endpoints are more informative than the number of choices displayed.

These measures do not predetermine who gains. Broad completion of receipts, limited costs including for small accounts and access to the assets users need would support a relatively smooth migration. Improvements in the provider’s administration could also be checked through subsequent reductions in inquiries and reconciliation work. Using the same population and period helps distinguish a transfer of burdens from an improvement in the whole process.

18. Three migration paths

Future outcomes are difficult to organise around a single direction, such as rising or falling trading volume. Even when affected balances leave the same provider, the assets received, migration costs and remaining dependencies can differ. The following three paths therefore keep the initial client cohort and assets fixed. They are hypotheses linking observations to explanations, not forecasts with assigned probabilities.

In the first path, destinations and processing arrangements are in place, enabling clients to reach the assets they need without substantial extra work. Original balances should fall, confirmed receipts increase and outstanding requests decline. Evidence of client-side outcomes as well as company notices would support the interpretation that operational adjustment did not develop into major market-wide friction.

In the second, migration progresses but costs and work concentrate in the remaining accounts. Much of the value may have moved while small accounts, corporate accounts or those using particular destinations remain unfinished. What is then needed is identification of the conditions where cases cluster and specific processing changes to address them, rather than another presentation of the overall progress rate.

In the third, clients move the same token to another place of custody without changing their asset type. Balances fall at the original provider, but dependence on the issuer and on future exchange channels remains. Distinguishing a completed custody transfer from an unchanged risk composition avoids loading too many meanings into the term “outflow.”

How to read a mixture of paths

All three can occur within a real client population. Aggregate balances combining clients who sell with those who transfer do not reveal which process creates the burden. Separating receipts by route and keeping a history when a client changes their choice avoids counting the same account as two successes. An interrupted request should also be connected to the route eventually chosen instead.

The regulatory documents considered here cannot establish which path will dominate. Company responses, the scale of affected accounts, client choices and destination conditions are needed first. If market prices move, distinctions between these paths should be considered separately from concurrent interest-rate changes and movements across crypto-assets, without extending the explanation beyond the evidence.

19. The next documents to read—and their denominators

When gathering the next evidence, read regulatory documents, company notices and processing records according to their separate roles. National authorities’ notices establish scope and supervisory assessments. Company notices identify which contracting entity changes which function. Neither alone shows whether clients have finished receiving assets; individual processing results or an explanation aggregating those results are needed.

A company notice should be examined for the affected clients, functions stopped or changed, outstanding requests, destinations and treatment of costs, as well as the token name. Recording page update dates helps distinguish client choices based on an earlier notice from options added later. Information collected on the same day should not be compared as if conditions were identical when it takes effect at different times.

Align the definitions behind completion counts

If figures are published, check whether the denominator comprises all affected accounts, only accounts that applied or only those deemed eligible for acceptance. Results also differ according to whether “complete” means accepted or confirmed as received. Companies using different definitions cannot be ranked on the size of their rates alone. First seek information allowing their figures to be compared at the same stage.

Quantity data present duplication and valuation problems too. One client can use several accounts, making account counts larger than person counts. Asset prices or conversion currencies can change values even when quantities remain the same. Attributing lower balance values to exit processing first requires separating quantity changes from price changes. If either is unknown, the conclusion should remain limited to the change in valuation.

Unverified information should be retained as unknown, with a reason. Unpublished client-specific costs cannot be classified as either zero or high. Even an aggregate may not be comparable with another if its client population is unidentified. Preserving that uncertainty shows which part of an earlier assessment new evidence could update and is more useful than filling gaps with guesses.

These checks differ from inferring a token’s compliance from its market price. Prices, volumes and transfer counts provide evidence of market and operational outcomes; they do not replace contracts or authorities’ determinations. Establishing the legal scope first and then following the corresponding clients and accounts reduces misreadings of both data and regulation.

20. Can migration preserve access to markets?

This market analysis focuses on what affected clients receive and what they continue to bear when services change. Declining balances at the original accounts are a starting point, but cannot alone establish the quality of migration. Distinguishing sale proceeds, redemption that extinguishes the issuer’s liability and movement of the same assets elsewhere clarifies what quantity changes mean.

SG Group sees this development as a migration problem requiring a fixed client cohort and operational endpoint, rather than as a uniform catalyst for prices to rise or fall. If clients receive the assets they need, the causes and allocation of costs are explained and the causes of outstanding requests are understood, the process can be assessed as preserving market access while winding down the original arrangements. More destinations matter less than whether the original clients could actually use them.

Information about unfinished work changes the assessment

A limited-burden assessment would be strengthened by evidence, for the same affected accounts, that receipts progressed including among small holders and that extra costs and exceptions were not concentrated. Conversely, strong progress by total value can conceal clients without an available route and balances or requests left open for long periods. Those cases require investigation beneath the aggregate. Market-price changes alone settle neither assessment.

The international significance extends beyond whether assets leave European accounts. The burdens on issuers, liquidity providers and receiving services differ when clients switch assets and when they use the same token through another route. If a lower balance at the original company becomes a larger balance managed elsewhere, global dependencies are rearranged. Judging whether dependency has declined requires following the assets to their destination.

Supervisory policy should be distinguished from company-level implementation results. Assessing monetary impacts, client losses and exit-completion rates requires processing outcomes and cost information for the affected accounts. Once such figures can be verified, the assessment can be updated using consistent accounts, assets, endpoints and costs. The next question is whether a change in services becomes a completed migration for clients.