Oslo

The Oslo DARTE session took place on January 31st, 2025, at Crucible Hub, Oslo. Organized with the support of the European Commission, Nordic Blockchain Association, Zumo, and tBt, this roundtable continued the series' mission of fostering legal clarity within MiCAR’s regulatory framework for crypto-assets. This session focused on the interplay between MiCA and PSD2, MiCA implementation challenges in Norway and the EEA, and the sustainability disclosure requirements under MiCAR.

The session opened with welcome remarks from Dr. Nina-Luisa Siedler, setting the stage for an engaging agenda. Romena Urbonaite, Chief Compliance Officer at Axiology, led the discussion on the regulatory overlap between MiCA and PSD2, analyzing the challenges of double authorization requirements for CASPs working with e-money tokens (EMTs). Magnus Jones of the Nordic Blockchain Association provided insights on MiCA implementation in Norway and the broader EEA, highlighting regulatory delays, challenges for market participants, and uncertainties around cross-border operations. Kirsteen Harrison, Head of Sustainability at Zumo, contributed a critical analysis on MiCAR’s sustainability disclosure requirements, addressing compliance complexities and the need for industry-driven standardization efforts.

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Interplay Between MiCA and PSD2

This session explored the regulatory overlap between MiCA and PSD2, particularly the challenges of double authorization requirements for CASPs dealing with e-money tokens (EMTs). Discussions focused on regulatory inconsistencies, supervisory challenges, and potential solutions to ensure compliance while reducing operational burdens.

Call to Actions

The EBA and ESMA should finalize and publish the no-action letter requested by the European Commission to prevent unnecessary dual authorization during the transition period.
The European Parliament should ensure that EMT transactions do not require PSD2 authorization if a CASP is already MiCA-compliant.
The industry should lead the creation of a taxonomy defining which activities fall under MiCA, PSD2, or both, providing practical compliance guidelines for CASPs.
NCAs should align supervisory practices to prevent conflicting interpretations of MiCA and PSD2.
Regulators should establish a clear and uniform approach for determining capital requirements when firms hold both MiCA and PSD2 licenses.

MiCA Implementation in Norway and the European Economic Area (EEA)

This session focused on the status of MiCA implementation in Norway and the broader EEA region, addressing regulatory delays, challenges for market participants, and uncertainties around cross-border operations.

Call to Actions

The EEA Committee should provide a concrete timeline for MiCA adoption in Norway, Liechtenstein, and Iceland to ensure regulatory certainty.
Norwegian authorities should confirm whether already registered VASPs can continue limited operations within the EU until MiCA licenses become available.
Given MiCA’s unclear enforcement approach, industry participants should create best practices for reverse solicitation compliance.
EEA firms should exchange insights and strategies on managing grandfathering discrepancies across jurisdictions.
Regulators from Norway, Liechtenstein, and Iceland should collaborate to ensure a harmonized MiCA implementation, avoiding competitive imbalances.

Sustainability Disclosures Under MiCAR

This session, presented by Kirsteen Harrison, Head of Sustainability at Zumo, examined the challenges CASPs face in addressing MiCAR’s sustainability disclosure requirements, highlighting regulatory uncertainty and the lack of implementation guidance.

Call to Action

CASPs with structured guidance on MiCAR’s sustainability disclosures.
Facilitate an industry-wide compliance toolkit compiling best practices, regulatory interpretations, and implementation examples, ensuring it remains a non-binding resource while addressing governance and liability considerations.
Develop a harmonized approach to ensure MiCAR’s sustainability disclosures are consistently applied across Member States.

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