EMA publications

The EMA frequently responds to government and European consultations on regulation that impacts the e-money and payment services industry. Sometimes, we also express our views on issues that are raised in the public domain where we feel it is important to provide an industry input.

Our publications reflect the views of the EMA as whole; individual members’ views may vary from time to time. The public consultation responses are listed below. For further information on these positions, please contact us.

Joint industry letter to ESMA and EU Commission on Authorisation Process for CASPs

The EMA co-signed a joint industry letter to ESMA and the European Commission on the authorisation process for Crypto Asset Service Providers (CASPs) under MiCA.

The letter addresses concerns over regulatory delays, inconsistent transitional measures, and potential service disruptions. It calls for harmonised authorisation requirements, extended transitional periods, and supervisory flexibility to ensure a smooth implementation of the MiCA framework, safeguarding consumer access and market stability.

Read the full letter here

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Joint industry letter to the Commission on CESOP

The EMA co-signed an industry letter to the European Commission addressing challenges in implementing the Council Directive (EU) 2020/284 of 18 February 2020, amending Directive 2006/112/EC as regards introducing certain requirements for payment service providers (CESOP Directive) and the associated mitigation measures.

The letter emphasises the need for streamlined registration processes, harmonised requirements across Member States, and a one-stop-shop reporting system. It also advocates for a moratorium on penalties during the initial compliance period, ensuring smoother adoption of CESOP reporting requirements.

Read the full letter here

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Joint industry letter on Eurosystem policy statement on non-bank PSP access

The EMA co-signed a joint industry letter to the European Central Bank expressing concerns over the Eurosystem policy on non-bank PSP access to central bank-operated payment systems and accounts. The letter advocates for a calibrated approach to safeguarding funds with central banks, addressing economic barriers to direct participation, and extending transitional periods to ensure business continuity and maintain competition in the financial services sector.

Read the full letter here

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