The European Banking Authority (EBA) has issued an opinion advising national competent authorities under PSD2 on what steps to take when the transition period linked to its No-Action Letter of June 2, 2025 ends on March 2, 2026.

The transition period, established under the EBA No-Action Letter of June 2, 2025, allows crypto asset service providers nine months to continue transacting electronic money tokens that qualify as payment services while submitting, and awaiting a response to, their application for authorisation under PSD2.

The new opinion sets out the conditions under which crypto asset service providers may continue offering electronic money tokens that qualify as a payment service after March 2, 2026, even if they do not yet hold a licence under the revised Payment Services Directive.

National competent authorities are advised to permit continued activity only where these conditions are met and to require providers that fail to meet them to discontinue such services.

Where necessary, authorities are advised to cooperate with the relevant national authority under the Markets in Crypto-Assets Regulation and or other national enforcement authorities to ensure compliance.

The opinion follows the earlier No-Action Letter, which was issued in response to a request from the European Commission seeking clarification on the interplay between PSD2 and MiCA in relation to crypto asset service providers transacting electronic money tokens that qualify as payment services.

Under that letter, providers were allowed to continue delivering such services without immediate second authorisation under PSD2, subject instead to a nine-month transition period for dual authorisation.

The letter also advised national competent authorities to consider only a subset of crypto asset services involving electronic money tokens as payment services, thereby reducing the number of providers requiring additional authorisation.

In addition, authorities were encouraged to apply a streamlined authorisation process using information submitted under MiCA, with the aim of reducing administrative burden for providers.

Since the publication of the No-Action Letter, more than 100 crypto asset service providers have approached national competent authorities informally or formally submitted applications for authorisation as payment service providers.

With the transition period nearing its conclusion and application volumes expected to vary across Member States, the authority has now issued the opinion to guide national competent authorities on how to prioritise authorisation efforts after March 2, 2026.

The move seeks to ensure regulatory clarity, maintain supervisory consistency and support an orderly shift to the full application of PSD2 requirements for electronic money token services.