Trading activity among European users on crypto platforms has significantly increased following the entry into force of the MiCA regulation, while a decline has been recorded in the U.S. ForkLog has gathered expert opinions on the reasons behind this divergence.

Konstantins Vasilenko, co-founder of Paybis, told Cointelegraph that EU investors have started making larger and more “deliberate” trades.

“It’s hard to ignore the timing. The MiCA licensing window opened on January 1, 2025. That same quarter, our volumes in the EU jumped by 70%, even though the number of transactions barely changed. That tells me the new money is bigger and more intentional,” he said.

Other platforms report similar trends. According to Kaiko, the share of retail clients in spot trading on Coinbase dropped to 18% from 40% in 2021. Meanwhile, crypto trading volume on Robinhood fell by 35% in Q1 2025.

Amid these shifts, Coinbase, OKX, and Gemini have already obtained licenses in the EU.

Problems in the U.S.

In the U.S., the market is held back by regulatory uncertainty. Despite statements from President Donald Trump, there is still no federal cryptocurrency law.

“The fragmented licensing system in each state, SEC lawsuits, and sudden delistings create uncertainty for users,” Vasilenko explained.

France — The New Leader

France stands out among EU countries with a 175% increase in crypto activity, according to Paybis. This growth was driven by the PACTE law, which came into force in 2019, requiring exchanges to register under AML procedures. Adoption in France is expected to reach 24% of the population in 2025.

Vasilenko believes the idea of a centralized "hub" is outdated. Operations can be distributed across various EU countries under the common MiCA framework.

He also said the U.S. could regain ground if it passes the GENIUS Act, noting that the law would do for U.S. retail investors what MiCA has done for Europeans.

The U.S. Isn’t Falling Behind

Technobit CEO Alexander Peresichan told ForkLog that he doesn’t expect a massive shift of capital and innovation from the U.S. to Europe. In his view, “America is currently shaping a highly attractive regulatory environment for doing business.”

“The interest in the EU is a result of the active work of local regulators who have created a clear legal framework. While these rules provide confidence for businesses, the U.S. still looks more attractive in the long term,” he said.

He doubts MiCA’s clarity will make the EU the new global crypto hub, adding that U.S. authorities are more loyal to the industry, and as long as Donald Trump is in charge, the U.S. will continue to attract crypto businesses.

Peresichan noted that the GENIUS Act could become a U.S. counterpart to MiCA. As an example, he cited JPMorgan, which has been considering launching its own stablecoin in anticipation of regulatory changes in the stablecoin sector.

However, he emphasized that the GENIUS Act is focused specifically on stablecoins, while the EU's approach under MiCA is broader and more global. He added that U.S. regulators have become more crypto-friendly, especially after Gary Gensler stepped down as head of the SEC.

Diversification, Not an Exodus

Bitget Research’s Chief Analyst Ryan Li confirmed that many crypto companies—including Bitget—are actively working to obtain licenses in the EU. Thanks to MiCA’s passporting system, companies can serve the entire EEA after a single regulatory approval—something not yet possible in the U.S., he noted.

Still, Li emphasized that this trend is not a mass exodus, but rather a diversification of business strategy. The U.S. still offers the deepest capital markets, and remains home to key funds, talent, and infrastructure—remaining the “juiciest piece” for crypto firms.

In Li’s view, MiCA is turning the EU into one of the global crypto centers, but not the exclusive leader. He argued it’s too early to talk about the U.S. losing its position, as American regulators—under a crypto-friendly Trump—are working to improve the attractiveness of the jurisdiction.

Li also noted that comparing the GENIUS Act with MiCA is inappropriate, as they serve different purposes. According to him, these initiatives have different scopes and are not directly comparable.

“If the GENIUS Act is about stablecoins and strengthening the dollar on the global financial stage, then MiCA is a broad regulatory package aimed at governing the entire crypto market, not just a specific part,” Li concluded.

EU’s Approach Not Conducive to Innovation

According to trader and Coen+ Telegram channel author Vladimir Coen, the rigid bureaucracy of the EU lags behind the pragmatic American strategy, which could lead to a migration of innovative companies to the U.S.

He noted that MiCA represents a comprehensive framework for the entire industry—exchanges, custodians, and crypto service providers—with strict licensing standards that mostly only large players can meet. In contrast, the GENIUS Act focuses exclusively on stablecoins, aiming to promote the dollar as a global payment tool and boost demand for U.S. Treasury bonds.

Coen explained that large companies obtaining EU licenses are primarily trying to capture a share of a massive, capital-rich market while it’s still relatively open. He also said that for Coinbase, this is part of a global expansion strategy led by CEO Brian Armstrong, following increased pressure from U.S. regulators.

However, Coen believes the European approach does not foster innovation.

“MiCA, in classic EU bureaucratic style, imposes too many restrictions. With such regulation, the EU has no chance of becoming the world’s crypto industry center,” he said.

He believes the main goals of MiCA are consumer protection, restructuring the market in favor of large, easily controlled players, anti-money laundering efforts, and capital retention within the EU. Innovation, he says, is near the bottom of the priority list.

In conclusion, Coen predicted that after the U.S. adopts its own presumably more liberal crypto regulation law—such as the Market Clarity Act—smaller Web3 companies will begin migrating from Europe to the U.S.

As a reminder, Coinbase was recently criticized for sponsoring a military parade in the U.S.