PSD2–MiCAR Overlap As The EBA Transition Period Ends

The European Banking Authority (EBA) published an opinion advising national competent authorities (NCAs) under the Revised Payment Services Directive (PSD2) on the supervisory approach to be taken once the transition period established by the EBA's No‑Action Letter of 2 June 2025 expires on 2 March 2026. During this nine‑month transition period, crypto‑asset service providers (CASPs) have been permitted to continue transacting in electronic money tokens (EMTs) that qualify as payment services while submitting, and awaiting a decision on, their applications for authorisation under PSD2.

Key insights

• The transition period in the EBA's No-Action letter comes to an end on 2 March 2026.