MiCA & TOFR Concluded - Measuring INATBA’s Impact - INATBA
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MiCA & TOFR Concluded – Measuring INATBA’s Impact

Finally, the world’s most impactful regulation on crypto assets is a reality!

Over the past two years, INATBA has been active on the Markets in Crypto Asset Regulation (MiCA). This was arguably the most important regulation that the Finance WG has worked on during that time, since it is the first international regulatory regime that shall span across the Single Market and influence the policy positions of multiple additional jurisdictions.

In addition to MiCA, the Transfer of Funds Regulation (TOFR), the regulation that imposes Anti-Money Laundering (AML) requirements to all Crypto Asset Service Providers (CASPs), was the second file that the Finance WG dedicated substantial resources on.
This week, both files concluded their trilogues and their final versions are now complete!

INATBA’s suggestions and positions were included in both of the files. You can find our MiCA position here, and our TOFR position here. To summarize, here are some of the positions that INATBA proposed which found a place within the two files.


  • Updated definitions – INATBA’s request to update and clarify definitions were implemented in the final form of the regulation.
  • Scope – DeFi and DAOs are out of the scope of MiCA. INATBA sought to also exclude NFTs, which were partially excluded. NFT Collections are under scope, and all CASP requirements befall their issuers.
  • Updated Definitions – INATBA’s request to update and clarify definitions were implemented in the final form of the regulation.
  • Threshold – the Threshold for transactions to unhosted wallets will be 1000 EUR instead of zero. This is a position that we proposed very early in the cycle. INATBA members would like to see all crypto asset transactions meet this threshold, but the compromise suits our positions and is welcomed.
  • Verification of Information for Unhosted Wallets – INATBA members stated that information required to be verified by CASPs must shift to a risk-based approach. This position was accepted into the TOFR.

The conclusion of the drafting of these two files is a monumental step for Crypto-Assets in Europe. On behalf of all of INATBA, we welcome the regulations and congratulate all parties who made these files a reality!

INATBA members are still eager to provide feedback on the level 2 and 3 regulations for both files.