The European Banking Authority (EBA) published an Opinion advising national competent authorities (NCAs) under the Revised Payment Services Directive (PSD2) on how to proceed once the transition period that is set in the EBA’s No-Action Letter of 2 June 2025 (EBA/Op/2025/08) comes to an end on 2 March 2026. The transition period allows crypto asset service providers (CASPs) nine months to continue transacting electronic money tokens that qualify as payment services while submitting, and awaiting the response to, their application for authorisation under PSD2.

The Opinion outlines the conditions under which NCAs are advised to allow CASPs to continue providing electronic money token (EMT)s that qualify as a payment service after 2 March 2026, while they do not (yet) hold a license under the PSD2. NCAs are further advised to require CASPs that do not meet all of these conditions to discontinue the provision of such EMT services. Where necessary, NCAs are advised to cooperate with the relevant national authority under the Markets in Crypto-Assets Regulation (MiCA) and/or other national enforcement authorities to ensure compliance.