In its Opinion EBA/Op/2025/08, issued in the form of a No-Action Letter , the European Banking Authority (‘EBA’) endeavoured to mitigate the increasing uncertainties on the matter through a transitional, nonbinding enforcement approach. While the initiative acknowledges the practical difficulties faced by the industry, it also accentuates the depth of the underlying legislative misalignment, thereby inviting a broader assessment of the architecture itself. The contribution examines the position of the EBA, highliting the critical issues relating to the coordination between the MiCAR and the payment service legislation
MINTO et al. (2025) studied this question.