On the 10th of June 2025, the European Banking Authority (EBA)
issued a No Action letter addressing a pressing issue faced by
crypto-asset service providers (CASPs): the regulatory overlap
between the Payment Services Directive (PSD2) and the Markets in
Crypto-Assets Regulation (MiCA) concerning electronic money tokens
(EMTs).
The letter offers both short-term regulatory relief and
long-term legislative direction aimed at avoiding unnecessary dual
authorisations
Transition Period and Temporary Relief
While PSD2 remains in force until the expected application of
PSD3 and the Payment Services Regulation (PSR), the EBA advises
national competent authorities (NCAs) not to require immediate PSD2
authorisation from CASPs that provide services related to
EMTs—specifically those relating to the transfer, custody,
and administration of EMTs. Authorisation requirements will apply
only from 2 March 2026 onwards.
