CLAIM-2026-08-08-04

The EBA advises that transfers of e-money tokens carried out on behalf of clients qualify as payment services, and that custody and administration of EMTs constitutes a payment service with the custodial wallet a payment account under PSD2, where it allows sending and receiving transfers of EMTs to and from third parties. Exchange of crypto-assets for funds or for other crypto-assets is excluded.

Why it matters

Turns an abstract question into a concrete one: a custodial agent wallet that pays third parties is a payment account, so the account-level duties apply to something teams currently treat as product config.

Sources

• europeanban2025opinion