EBA Opinion related to the interplay between PSD2 and MiCA

On 12 February 2026, the European Banking Authority (EBA) issued a key Opinion on the end of the transition period under its No-Action Letter concerning the interplay between PSD2 and MiCA. Three scenarios are now clearly defined for CASPs providing EMT services that may qualify as payment services: 1️⃣ Authorisation obtained (PI/EMI) or acting via a PSP → activity may continue within authorised scope 2️⃣ Authorisation applied for but not yet granted → temporary continuation under strict conditions 3️⃣ No application or conditions not met → immediate cessation of the relevant services