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ARTICLE · 19 FEBRUARY 2026

MiCAR/PSD2 Interplay: EBA Opinion On The No Action Transition Period End

William Fry LLP
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The transition period ends on 2 March 2026 and the recent EBA opinion may be relevant to crypto asset service providers...

IrelandFinance and Banking
Shane Kelleher
Shane Kelleher
Louise McNabola
Louise McNabola
John O'Connor
John O'Connor
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On 12 February 2026, the European Banking Authority (EBA) published an opinion on actions for national competent authorities (NCAs) to take at the end of the transition period set in its 2 June 2025 no action letter regarding the interplay between the second Payment Services Directive (PSD2) and the Markets in Crypto Assets Regulation (MiCAR).

The transition period ends on 2 March 2026 and the recent EBA opinion may be relevant to crypto asset service providers (CASPs) that transact electronic money tokens (EMTs).

For further information on the June 2025 EBA no action letter, please see our article here.

In the opinion, the EBA guides NCAs by:

  • Setting out the conditions under which NCAs can allow CASPs to continue providing EMTs (that qualify as a payment service) after 2 March 2026, while they do not yet hold a licence under PSD2

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