EBA publication of its Opinion advising NCAs on actions to take at the end of the transition period under its No-Action Letter on the interplay between PSD2 and MiCAR, 12 February 2026

On the 12^th of February 2026, the European Banking Authority published an Opinion laying down the conditions under which national competent authorities (NCAs) are advised to allow crypto-asset service providers (CASPs) to continue providing e-money tokens (EMTs) which qualify as payment services after the transition period established in the EBA’s No-Action Letter of the 2^nd of June 2025 ends on the 2^nd of March 2026, while these CASPs (still) do not hold a license under the Revised Payment Services Directive (2015/2366/EU, PSD2). Moreover, the Opinion advises NCAs to require CASPs which do not meet all of these conditions to discontinue the provision of such EMT services and, where necessary, to cooperate with the competent national authorities under the Markets in Crypto-Assets Regulation (2023/1114/EU, MiCAR) and/or other national enforcement authorities to ensure compliance.