How do PSD3 capital requirements affect crypto companies under MiCA?
PSD3 introduces significant capital requirement challenges for crypto companies already subject to MiCA regulations, as these requirements may be cumulative rather than alternative. When Crypto-Asset Service Providers (CASPs) handle electronic money tokens, they must maintain capital buffers that satisfy both PSD3's payment institution standards and MiCA's crypto-asset service provider requirements. This stacking effect creates a substantial financial burden, as companies cannot simply meet the higher of the two requirements but may need to combine them. The European Banking Authority's 2025 opinion clarified that capital adequacy must be assessed under both frameworks, potentially requiring companies to hold significantly more regulatory capital than anticipated. This affects not just initial authorization but ongoing compliance, as supervisory authorities will expect maintained capital levels under both regimes. Companies must stress-test their financial models to ensure they can withstand these cumulative requirements while remaining operational. The March 2026 deadline adds urgency to this capital planning, making immediate financial assessment and buffer strengthening essential for crypto firms operating in the EU market.
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