CLAIM-2026-08-08-03

MiCA Article 48(2) provides that e-money tokens shall be deemed to be electronic money, and PSD2 Article 4(25) includes electronic money within the definition of funds; therefore EMTs are funds for PSD2 purposes.

Why it matters

The whole payments analysis hangs on this chain. If the token is not an e-money token, PSD2 does not bite in this way and the practitioner advice changes.

Sources

• europeanban2025opinion