March 2026

On 4 December 2025, the European Commission published the Market Integration and Supervision Package. A landmark set of legislative proposals under the Savings and Investments Union strategy, introducing significant amendments to the DLT Pilot Regime and MiCAR, among other pieces of EU financial legislation.

In response to the Commission’s call for feedback, EDFA’s Blockchain Working Group coordinated an open letter bringing together perspectives from fintech associations and companies from across the EU. The letter was co-signed by 24 associations and 3 companies spanning Belgium, Bulgaria, the Czech Republic, Estonia, France, Germany, Hungary, Italy, Latvia, Lithuania, the Netherlands, Norway, Poland, Romania, Spain, Sweden, and beyond.

On the DLT Pilot Regime, the letter welcomes the proposed scope expansion and threshold simplification, and calls for mandatory interoperability standards between DLT market infrastructures and traditional market infrastructure to avoid liquidity fragmentation. It also raises a significant regulatory gap in the treatment of DLT Notary and Central Maintenance Services: nationally licensed DLT registrars in Germany, Luxembourg, and Italy, entities that have been providing these exact services under rigorous national supervision since 2021, are inadvertently excluded from the current draft. The letter calls on the Commission to introduce a recognition pathway, grandfathering provisions, an ESMA equivalence assessment, and proportionate authorisation requirements to address this.

On MiCAR, the letter supports centralising CASP supervision under ESMA as a step towards consistency across the EU, but flags a structural asymmetry: crypto-native firms would face harmonised EU-level oversight while traditional financial institutions offering identical crypto-asset services remain under divergent national supervision. The letter proposes an opt-in mechanism as a practical solution.

We thank all co-signatories for their engagement and contribution.