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ARTICLE · 01 APRIL 2026

PSD2 Implications For CASPs Dealing With E-Money Tokens

A.G. Erotocritou LLC
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On 3 February 2026, the Central Bank of Cyprus ("CBC") published an announcement (available here) following the European Banking Authority's No Action Letter (available here) on the interplay between the PSD2...

CyprusFinance and Banking
A.G. Erotocritou LLC
A.G. Erotocritou LLC
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On 3 February 2026, the Central Bank of Cyprus (“CBC”) published an announcement (available here) following the European Banking Authority’s No Action Letter (available here) on the interplay between the PSD2 (Directive (EU) 2015/2366) and the MiCA Regulation (Regulation (EU) 2023/1114). The No Action Letter focuses on the treatment of crypto-asset service providers (“CASPs”) that transact electronic money tokens (”EMTs”).

According to the No Action Letter, the European Banking Authority (“EBA”) considers the following activities to constitute payment service under PSD2:

  1. Transfer of crypto assets where they entail EMTs and are offered and carried out by the entities on behalf of their clients.

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