Response to consultation on Regulatory Technical Standards on supervisory colleges under MiCAR
Go back
Question 5: Do you agree with the criteria proposed in Article 3 of the draft RTS for assessing when a significant ART or a significant EMT is “used at large scale” in a Member State, as referred to in Article 119(2), point (l) of MiCAR? If not, please provide your reasoning and the underlying evidence and suggest an alternative approach.
The current thresholds, though aiming for uniformity, may not capture the uneven pace of digital adoption across the EU. We would propose a framework that goes beyond transaction volumes and population metrics, to also consider the depth of digital finance adoption and integration in each Member State. This approach not only addresses potential regulatory imbalances but also aligns with the EBA’s objectives of ensuring market integrity and consumer safety. We hope to engage with the EBA and to contribute to a nuanced regulatory dialogue. Paxos has always sought collaboration with authorities to develop criteria that are both comprehensive and adaptable and, in this case, will support the EU’s digital finance ecosystem’s growth.