Response to consultation on draft RTS on the minimum content of the governance arrangements on the remuneration policy under MiCAR

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Question 1. Are the definitions within Article 1 appropriate and sufficiently clear?

Digital Currencies Governance Group (DCGG) is a trade association that represents digital assets issuers and service providers in the European Union and the United Kingdom. Our mission is to facilitate an open dialogue and encourage communication between policymakers and digital asset experts to support the design of a sound and proportionate regulatory framework that ensures safety for all market participants. DCGG views the definitions within Article 1 as appropriate and sufficiently clear.

Question 2. Are the provisions within Article 2 appropriate and sufficiently clear?

DCGG views the definitions within Article 2 as appropriate and sufficiently clear.

Question 3. Are the provisions within Article 3 appropriate and sufficiently clear?

DCGG views the definitions within Article 3 as appropriate and sufficiently clear.

Question 4. Are the criteria of identification of staff appropriate and sufficiently clear?

DCGG views the proposed criteria of identification of staff as appropriate and sufficiently clear.

Question 5. Are the provisions within Article 5 appropriate and sufficiently clear?

DCGG views the proposed provisions of variable remuneration overall as appropriate and sufficiently clear. It appears to be mostly aligned with the requirements for other financial institutions. However, the minimum deferral period of at least 40% of the variable remuneration of at least 3-5 years might be reduced to 2-5 years, as there is no equivalent minimum period required for other financial institutions.

Question 6. Is the possibility of paying a part of variable remuneration in significant asset-referenced tokens issued by the issuer appropriate also considering the still limited market experience on these instruments?”

In DCGG’s view, the EBA’s proposal for an additional option of payout of variable remuneration, namely in significant asset-referenced tokens issued by the issuer is sound, and we welcome the opportunity for firms to diversify their remuneration payout options and make the choice of what based on what is most suitable in line with their internal structures, business objectives and policies. On payout in significant ARTs issued, we fully support that such an option can contribute to reducing operational risks and could facilitate more effective liquidity management as these assets start to circulate more widely in the EU market. From our perspective, this could be instrumental to the growth and legitimacy of significant ARTs in Europe, and would also incentivise remunerated staff to care more about the viability of the tokens themselves, promoting a positive feedback loop. Last but not least, some of the stablecoins have been in the market for almost 10 years.

Name of the organization

Digital Currencies Governance Group (DCGG)