What are the dual authorization requirements for crypto companies under PSD3 and MiCA?
Under the new EU regulatory framework, Crypto-Asset Service Providers (CASPs) dealing with electronic money tokens face dual authorization requirements from both PSD3 (and its accompanying Payment Services Regulation) and MiCA (Markets in Crypto-Assets Regulation). This means crypto companies must apply for authorization under both regulatory regimes simultaneously, creating a complex compliance landscape. The European Banking Authority clarified in June 2025 that these requirements are cumulative rather than alternative, forcing CASPs to navigate two distinct sets of rules covering similar activities. This dual compliance obligation represents a significant operational challenge, as companies must establish governance structures, risk management frameworks, and reporting systems that satisfy both PSD3's payment services standards and MiCA's crypto-specific regulations. The financial implications are particularly burdensome, as capital requirements may need to be stacked rather than satisfied once, potentially doubling the regulatory capital needed. Companies must prepare for this dual authorization process well before the March 2026 deadline to avoid operational disruptions and regulatory penalties.
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