Paris 2.0

The Paris 2.0 DARTE session took place on April 14th, 2026, at the Bank of New York's Board Room in Paris, in collaboration with the European Commission, Asensi Abogados, BNY, Cardano Foundation, and Notabene. This edition brought together regulators, legal practitioners, and digital asset infrastructure providers to examine some of the most pressing open questions in European digital asset regulation, with a particular focus on the practical and supervisory challenges that persist as MiCA enters its implementation phase.

The roundtable explored four interconnected themes at the frontier of the EU's evolving regulatory architecture. The session opened with a keynote by Frederik Gregaard (Cardano Foundation), who set the tone with a challenge to the prevailing assumption that more regulatory text produces more clarity, arguing instead for regulatory quality over quantity and for industry's role as a co-designer of interpretive frameworks rather than a passive respondent to consultation. Juan Ignacio Ibañez (MiCA Crypto Alliance) then presented on the EU legal taxonomy of liquid staking tokens, illustrating in concrete terms the structural fragility of classification under parallel regimes and the compliance risks that flow from taxonomic instability.

Marina Villalonga (Asensi Abogados) continued the technical discussions with a deep dive into the MiCAR/PSD3/PSR perimeter for EMT-based payment services, building on the São Paulo DARTE discussion and examining how the new legislative package reshapes without resolving the dual-regime burden, with particular attention to the divergent national implementations already creating arbitrage risks across Member States. James Cunningham (BNY) followed with an examination of the conditions required to move multi-jurisdictional stablecoin issuance from legal permissibility to operational reality, taking the Joint Interpretive Note published following Helsinki as a settled legal foundation and turning to the foundational principles that must be agreed before multi-issuance can scale. Catarina Veloso (Notabene) closed the technical sessions with a presentation on the two unresolved regulatory questions around self-hosted wallet treatment in the EU, proposing a purposive distinction between personal wallets and programmatic addresses as the practical path through the TFR's operational ambiguities. The session concluded with a final keynote by Peter Kerstens (European Commission, DG FISMA) and closing remarks by Mariana de la Roche.

The Paris 2.0 edition reinforced DARTE's position as a trusted venue for shaping Europe's digital asset regulatory landscape through grounded, multi-stakeholder dialogue. As MiCA's implementation deepens and the PSD3/PSR package moves toward application, the session underscored that the next phase of European digital asset regulation will be defined not by new legislative text, but by the quality of interpretation, the consistency of supervisory practice, and the willingness of industry and regulators to build shared frameworks together.

Full Report

Regulatory Issues for Payment Services: The MiCAR/PSD3/PSR Perimeter for EMT-Based Payment Services

The first session continued the discussion on EMT-based payment services initiated at the São Paulo DARTE edition, examining with greater depth how the PSD3/PSR package reshapes, without resolving, the dual-regime burden for firms operating in the EU market. Participants discussed the confirmed treatment of EMTs as electronic money under the new legislative framework, the fast-track authorisation channel introduced for MiCAR-licensed CASPs, and the significant divergences already visible across Member States in licensing structure, application processes, and tax treatment. The session also examined practical approaches for firms navigating the interim period and raised the case for a tiered, proportionate entry pathway for payment services within the MiCAR framework.

Next Steps on Multi-Jurisdictional Stablecoin Issuance

The second session built on the legal foundation established by the Joint Interpretive Note published following the Helsinki DARTE edition, taking multi-jurisdictional EMT issuance as a legally settled question and turning to the foundational principles that must be agreed before it can be operationalized at scale. Participants challenged developed-market assumptions about stablecoin use cases, examined the structural mismatch between 1:1 reserve requirements and realistic redemption behavior, and discussed the significant divergence between EU, UK, and US approaches to reserve composition and custody. The role of US banks in blocking access to the dollar rail was identified as a concrete geopolitical and commercial constraint that legal architecture alone cannot resolve.

Self-Hosted Wallet Treatment in the EU: Two Unresolved Regulatory Questions

The third session addressed two structural ambiguities in the EU's regulatory treatment of self-hosted wallets that create significant operational friction for CASPs without delivering proportionate compliance or consumer protection benefits. Participants examined the TFR's overly broad definition of self-hosted addresses, which captures smart contracts and DeFi protocols alongside personal wallets, and discussed the practical impossibility of applying information collection obligations where no identifiable counterparty exists. The session also addressed the scope of EBA Travel Rule Guidelines on third-party self-hosted wallet transactions above €1,000, reaching consensus that these guidelines provide operational options within a risk-based framework rather than creating standalone identity verification obligations.

Call to Actions

Develop a clear taxonomy for EMT-related activities and wallet typologies, providing practical criteria to distinguish transfers, payments, exchange activities, and internal operations, with EBA guidance calibrated to the PSD3/PSR framework and the interim period.
Advance NCA coordination to prevent regulatory arbitrage under PSD3/PSR, ensuring that the framework's harmonisation objective is achieved through consistent supervisory implementation across Member States.
Establish a model MiCAR application framework and advocate for a proportionate entry pathway for payment services, allowing CASPs to access payment functionality under tiered rather than full PI/EMI prudential requirements.

Call to Actions

Agree on foundational principles for stablecoins before advancing multi-issuance frameworks, explicitly recognizing that use cases differ materially across economic contexts and that regulatory design must reflect those differences.
Reform reserve policy toward a coherent, risk-calibrated framework, addressing the EU's deposit concentration limits and the divergence between commercial and central bank money requirements through coordinated international standard-setting.
Advance supervisory convergence on multi-jurisdictional issuance as a legally settled question, ensuring that the forthcoming MiCA consultation process is used to embed legal clarity into formal guidance rather than reopen the threshold question of permissibility.

Call to Actions

Adopt a purposive distinction between personal self-hosted wallets and programmatic addresses, reflected in EBA guidance and CASP compliance frameworks, with the risk-based approach under Article 19a AMLD as the governing standard for programmatic addresses.
Clarify the scope of EBA Guidelines on third-party self-hosted wallet transactions as risk-based rather than mandatory, making explicit that identity verification is not automatically triggered by the €1,000 threshold but by the risk assessment under Article 19a.
Ensure compliance frameworks support rather than undermine adoption, replacing disproportionate interpretations that effectively prohibit direct transfers to third-party wallets with proportionate, risk-based alternatives that protect users without degrading the utility of the technology.