PARIS, Feb. 12, 2026 — The European Banking Authority (EBA) published an Opinion on the end of the No-Action Letter transition period, advising national competent authorities on supervisory actions as the transition period under its No-Action Letter concerning the interaction between the Markets in Crypto-Assets Regulation (MiCA) and the Revised Payment Services Directive (PSD2) concludes.
According to the EBA, the transition period under the No-Action Letter concludes on 2 March 2026.
Background to the no-action letter
The No-Action Letter, issued on 2 June 2025, provided supervisory guidance in relation to crypto-asset service providers (CASPs) engaging in services involving e-money tokens (EMTs) that qualify as payment services under PSD2.
The No-Action Letter provided for a temporary period during which CASPs could continue providing certain EMT-related services while seeking authorisation under the applicable payment services framework.
Supervisory actions after 2 March 2026
In its Opinion, the EBA advises national competent authorities to assess, on a case-by-case basis, whether CASPs should be permitted to continue providing EMT services that fall within the scope of PSD2 after the end of the transition period.
The Opinion indicates that continued provision may be considered where a CASP has submitted an application for authorisation under PSD2 and is making progress toward meeting regulatory requirements, and where no material supervisory concerns are identified.
Where these conditions are not met, the EBA states that competent authorities should ensure that such services are discontinued in accordance with the applicable legal framework.
Coordination between authorities
The Opinion also refers to cooperation between authorities responsible for supervising MiCA and those overseeing PSD2 in order to promote consistent supervisory outcomes and avoid regulatory gaps.
Regulatory Context
MiCA establishes a harmonised regulatory regime for crypto-asset service providers, asset-referenced tokens and e-money tokens within the European Union.
PSD2 governs payment services across the EU. The EBA Opinion advises national competent authorities on how to supervise EMT-related activities that may fall within the scope of both PSD2 and MiCA once the transition period ends.
