Crypto-assets, which began as a technological alternative to traditional finance, have rapidly evolved into a central element of the global financial system. This rise has forced governments to address crypto-assets not only as an economic phenomenon but also as a legal and regulatory challenge. The European Union (EU) responded to this development by adopting the Markets in Crypto-Assets Regulation (MiCA), establishing a harmonized legal framework for its member states. Turkey, on the other hand, introduced its Law No. 7518 in 2024, creating its first comprehensive legal basis for the crypto-asset market.

While both frameworks rely on similar concepts, they diverge significantly in terms of legal approach, scope, and regulatory philosophy. This article examines the key differences between MiCA and Law No. 7518, highlighting Turkey’s flexible transition period and potential alignment with the EU in the future.

Legal Framework of Crypto-Assets

The EU aims to create a uniform regulatory landscape for crypto-assets through MiCA. Its objectives include strengthening investor protection, ensuring market stability, and creating a level playing field for financial actors across member states. MiCA clearly distinguishes between Asset-Referenced Tokens (ART), E-Money Tokens (EMT), and other types of crypto-assets.

Turkey’s Law No. 7518 reflects this classification indirectly. Instead of embedding the distinction in the legal text, it outlines the framework in the general preamble, leaving many details to be regulated by the Capital Markets Board (CMB). This flexible approach allows the Turkish legal system to adapt its regulations as the market evolves.

Terminology and Legal Philosophy

MiCA defines a crypto-asset as “a digital representation of a value or a right that can be transferred and stored electronically.”
In contrast, Law No. 7518 uses the term “intangible asset.” This difference is more than linguistic—it reflects two distinct regulatory philosophies:

• EU approach: centered on financial stability, the protection of the euro, and the integrity of the single market.

• Turkish approach: focused on legal grounding, flexibility, and integration with domestic private law.

Stablecoins and Asset-Referenced Tokens

Under MiCA, stablecoins (ARTs) are subject to strict requirements designed to protect the eurozone’s monetary stability. Issuers must meet high capital requirements and are subject to intense regulatory oversight.

Law No. 7518 uses the broader term “stable crypto-assets,” also encompassing reserve asset combinations. Turkey’s more flexible stance reflects its position as a non-reserve currency country and its willingness to encourage innovation in this space.

CASPs and Market Infrastructure

MiCA sets out a detailed framework for Crypto-Asset Service Providers (CASPs), including licensing, capital adequacy, internal controls, and transparency requirements.

In Turkey, the definition of CASPs is more general, and the regulatory details are delegated to the CMB. While this can lead to temporary regulatory gaps, it also gives the Turkish regulator room to shape the rules dynamically in response to market conditions.

Wallets and Platforms

Law No. 7518 clearly defines the concept of a “wallet,” aiming to close the legal gaps exposed by earlier market failures (such as exchange collapses). MiCA does not define wallets explicitly; this area is left to member states.

Similarly, while MiCA addresses trading platforms through the concept of “trading venue operation,” Turkish law uses more direct terminology, providing legal clarity in this area.

Economic Implications of Legal Choices

Turkey’s flexible regulatory structure is designed to foster innovation without overburdening the market. TL-based stablecoins could play a significant role in tourism, cross-border payments, and trade, giving Turkey strategic leverage in the digital finance landscape.

In contrast, the EU’s stricter stance aims to safeguard the euro’s role as a global currency and to prevent systemic financial risks. MiCA is therefore expected to set international regulatory standards far beyond the EU.

Future Outlook: Alignment and Opportunities

Given Turkey’s ongoing alignment process with the EU acquis, Law No. 7518 is expected to evolve and gradually mirror MiCA’s structure. Key developments likely to shape this process include:

• Establishing a clear licensing regime for CASPs,

• Refining EMT and ART definitions with technical standards,

• Regulating NFTs, algorithmic stablecoins, and DAOs,

• Clarifying ownership, collateral, and enforcement rules in private law.

Such steps would strengthen regulatory certainty and support Turkey’s integration into the international crypto ecosystem.

Conclusion

MiCA and Law No. 7518 reflect different legal traditions and economic priorities but share a common goal: to create transparent, predictable, and secure markets for crypto-assets. The EU’s model is based on financial stability and uniformity, while Turkey’s framework emphasizes flexibility and gradual adaptation.

Over time, closer alignment between these two approaches will strengthen investor confidence and enhance Turkey’s position in the global digital finance landscape. As crypto-assets continue to expand globally, legal systems will inevitably move toward greater harmonization.