Bitkom Reply to the third MiCAR policy batch of EBA

Bitkom has replied to the European Banking Authority (EBA) consultations on draft Regulatory Technical Standards (RTS) for Markets in Crypto-Assets Regulation (MiCAR), addressing own funds requirements and stress testing for asset-referenced tokens and e-money tokens issuers, alongside adjustments for significant issuers. While we recognize the complexity faced by authorities to assess the risk associated with issuers of asset-referenced tokens or e-money tokens, those authorities must retain the flexibility to adjust own fund requirements according to the actual risks. We believe that the heightened own fund requirements significantly impact business operations, especially for crypto asset service providers with limited access to capital markets. While a one-year timeframe is feasible, shorter durations are impractical, highlighting the distinct challenges faced by these entities.