On 12 February 2026, the European Banking Authority (EBA) issued an Opinion clarifying the regulatory position following the expiry of the transition period introduced under its June 2025 No Action Letter.
The Opinion addresses the interaction between MiCAR and PSD2 in relation to electronic money tokens (EMTs), which fall under a dual regulatory classification. It outlines a three-scenario framework covering authorised CASPs, applicants with pending authorisations (subject to conditions), and non-compliant entities required to cease EMT payment services from 2 March 2026.
The Opinion reinforces supervisory coordination and marks an important step in aligning crypto-asset and payment services oversight across the EU.