FIA EPTA welcomes the opportunity to respond to the ESMA Consultation Paper on Technical Standards specifying certain requirements of the Markets in Crypto Assets Regulation (MiCA). FIA EPTA members believe the draft RTS and ITS set out a balanced approach. However, FIA EPTA members believe further proportionality should be considered, in regard to the requirement to provide a programme of operations for the following three years. In addition, FIA EPTA members would welcome clarity on Articles 3 and 4 and the implementation of MiCAR and DORA, as DORA is not yet implemented when MiCAR will become into force.
