<aside> đź’ˇ In the past years, we have submitted numerous position papers, official responses and comments on the most urgent topics to communicate the needs of the industry, explain the risks of not getting regulation right and provide concrete solutions for the issues at hand.

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We have discussed with the European Commission, the Parliament, The Council and ESMA, and specific national competent authorities and Ministries in some member states. Namely, we have worked on the following topics:

Position papers shared with the policymakers and industry stakeholders:

  1. February 2024: We urged the European Commission to clarify the application of the PSD2 and PSD3 provisions to the EMT as defined under MiCA Regulation. This Joint Industry Letter was submitted to the regulators along with other organisations.
  2. November 2023: Along with other EU advocacy groups, we published a Manifesto for Blockchain: Embracing its potential in the European Union.
  3. May & June 2023: We’ve shared multiple positions during the AMLR negotiations. See our position paper here and our response to the EU Commission’s non-paper here;
  4. May 2023: The Data Act: Smart contracts implications for the future of innovation in Europe;
  5. February 2023: Anti-Money Laundering Regulation: EUCI’s position;
  6. January 2023: DAOs (Decentralized Autonomous Organisations): a public call for evidence published by the UK Law Commission;
  7. July 2022: MiCA and NFTs: Final comments on potential NFT inclusion in MiCA;
  8. June 2022: Feedback to the European Commission on the Digital Euro;
  9. May 2021: EUCI’s Comments on Digital Euro for Policy Make; Ensuring the future competitiveness of the Euro in a decentralized digital economy
  10. February 2021: MiCA and DeFi: Why Europe needs to get on the front foot of crypto innovation;
  11. February 2021: MiCA and Stablecoins: Money on Blockchain. Promoting Europe’s competitiveness through the development of a euro-stablecoin market;
  12. January 2021: Feedback to the European Commission on Financial Services - EU regulatory framework for crypto-assets;
  13. December 2020: DLT Pilot Regime: Shortcomings and improvement proposals;
  14. December 2020: MiCA: Summary of shortcomings and improvement proposals.
  15. October 2020: Draft general position paper on the two texts (MiCA Halts Innovation in Crypto-Finance)

Responses to the Regulators’ Reports and Discussion Papers:

  1. 4 March 2024: Feedback on public consultation regarding Digital Operational Resilience Act (DORA), RTS on Subcontracting and RTS on threat-led penetration testing (TLPT)
    1. 7 March 2024: Feedback to EBA regarding public consultation on Conflict of Interest