A MiCA authorisation does not necessarily close the licensing question for a crypto-asset service provider. Where the services touch electronic money tokens and those services qualify as payment services, a second authorisation regime engages, and the firm can find itself owing a separate application to a separate regulator under a separate body of EU law.
That is the operative tension behind CySEC Circular C756. The Circular routes an EU-level development, the European Banking Authority's Opinion on the interplay between PSD2 and the MiCA Regulation, into a concrete set of duties for CASPs in Cyprus, with a near-term filing deadline already in the past for some firms by the time many will read this.
The mechanism matters more than the announcement. A CASP that assumed MiCA was the whole of its regulatory perimeter may have misjudged the scope, and the cost of that misjudgment is measured in unlicensed activity.
What C756 says
CySEC issued Circular C756 on 16 February 2026, addressed to crypto-asset service providers and applicant CASPs, and expressly further to its earlier circular C722. CySEC Circular C756 (16 February 2026)
The Circular informs CASPs that on 3 February 2026 the Central Bank of Cyprus published an Announcement following the EBA's Opinion on the interplay between Directive (EU) 2015/2366 (PSD2) and Regulation (EU) 2023/1114 (the MiCA Regulation) in relation to CASPs transacting electronic money tokens. CySEC Circular C756 (16 February 2026)
In other words, CySEC is not legislating here. It is relaying the CBC's position, which itself follows an EBA Opinion, and directing CASPs to act on it. The Circular closes by encouraging interested parties to consult the full text of the CBC's Announcement and to inform CySEC of the actions taken. CySEC Circular C756 (16 February 2026)
The substance to act on sits in three layers: a classification question, a licensing consequence, and a set of dates.
The PSD2 mechanism: when a crypto service becomes a payment service
The pivot is whether a crypto-asset service offered by the firm qualifies as a payment service. PSD2 is the EU's payment-services framework, Directive (EU) 2015/2366. MiCA, Regulation (EU) 2023/1114, is the EU's markets-in-crypto-assets framework. The EBA Opinion addresses how the two interact specifically where CASPs transact electronic money tokens. CySEC Circular C756 (16 February 2026)
EMTs are the category of crypto-asset that references a single official currency, and it is precisely that money-like character that creates the overlap. When a firm moves EMTs on behalf of clients, the activity can resemble the transfer or holding of funds that PSD2 was built to regulate.
The consequence in the CBC's framing is direct:
→ If the crypto-asset services offered qualify as payment services, they are subject to licensing from the CBC. → Unless other arrangements with an eligible payment service provider are made. → Where a CASP needs authorisation as a payment institution to provide the services in question, the relevant application form must be completed and submitted to the CBC. CySEC Circular C756 (16 February 2026)
So the same EMT-related activity can sit inside MiCA and inside PSD2 at once. MiCA authorisation governs the crypto-asset service. A payment-institution authorisation from the CBC, or a qualifying arrangement with an eligible PSP, governs the payment-service layer. The two are not interchangeable.
The self-assessment duty
The Circular does not let firms wait to be told. The CBC's Announcement requests that CASPs conduct a self-assessment on whether the crypto-asset services they offer qualify as payment services, as per the provisions of the No Action letter, and are therefore subject to CBC licensing unless other arrangements with an eligible PSP are made. CySEC Circular C756 (16 February 2026)
The burden is on the firm to characterise its own activity. That is a familiar but demanding posture: the regulator sets the test, the firm applies it to its actual service map, and the firm carries the consequences of getting the classification wrong.
For a practitioner, the self-assessment is not a tick-box. It is a service-by-service mapping of every EMT-touching flow against the payment-services concept, with a documented conclusion for each, because the downstream obligation, a CBC application, depends entirely on the answer.
The timeline: three dates that bound the decision
C756 fixes the firm's position against a short sequence of dates, and they do not all run the same way.
→ 3 February 2026: the CBC publishes its Announcement following the EBA Opinion. CySEC Circular C756 (16 February 2026) → 16 February 2026: CySEC issues Circular C756 relaying the CBC's position to CASPs. CySEC Circular C756 (16 February 2026) → 20 February 2026: CASPs already offering the specific EMT-related crypto-asset services that qualify as payment services must submit a relevant application for authorisation to the CBC. CySEC Circular C756 (16 February 2026) → 1 March 2026: the transitional period provided in the No Action Letter ends, after which the EBA will issue further guidance, in due time, on the implications for CASPs. CySEC Circular C756 (16 February 2026)
There is also a separate, longer national track. By footnote, the Circular references CySEC MiCA crypto-asset regulated entities and crypto entities operating under the national transitional regime until 1 July 2026, in accordance with Article 143(3) of the MiCA Regulation. CySEC Circular C756 (16 February 2026)
The two transitional clocks should not be confused. The No Action Letter transitional period ends on 1 March 2026 and is the trigger for further EBA guidance. The national transitional regime running to 1 July 2026 under Article 143(3) MiCA is a separate MiCA-side accommodation, not an extension of the CBC payment-services filing window. CySEC Circular C756 (16 February 2026)
Practitioner action points
→ Map the perimeter. Inventory every service that touches electronic money tokens and treat each as a candidate payment service until the self-assessment concludes otherwise.
→ Run the self-assessment against the No Action letter's provisions, document the classification for each EMT-related service, and retain the reasoning. CySEC Circular C756 (16 February 2026)
→ Decide the route for any qualifying service: a CBC payment-institution authorisation, completed on the relevant application form and submitted to the CBC, or other arrangements with an eligible PSP. CySEC Circular C756 (16 February 2026)
→ Treat the 20 February 2026 date as binding for firms already offering qualifying EMT-related services, and engage the CBC immediately where that date has passed. CySEC Circular C756 (16 February 2026)
→ Watch for the further EBA guidance expected after the No Action Letter transitional period ends on 1 March 2026, and keep CySEC informed of the actions taken. CySEC Circular C756 (16 February 2026)
→ Read the CBC's full Announcement, which the Circular directs interested parties to consult, rather than relying on the relay alone. CySEC Circular C756 (16 February 2026)
The throughline is that a single EMT-related service can carry two authorisations and two regulators. Confirming which obligations attach, and tracing each to its instrument, is exactly the kind of perimeter question OmniLaw is built to answer. Primary sources, not summaries.
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FAQ
Does a MiCA authorisation cover EMT-related payment services?
Not on its own, per C756. Where a CASP's EMT-related crypto-asset services qualify as payment services, they are subject to licensing from the CBC unless other arrangements with an eligible PSP are made, which sits alongside the MiCA position rather than being satisfied by it. CySEC Circular C756 (16 February 2026)
What is the deadline to apply to the CBC?
CASPs already offering the specific EMT-related crypto-asset services that qualify as payment services must submit a relevant application for authorisation to the CBC by 20 February 2026, according to C756. CySEC Circular C756 (16 February 2026)
What happens after 1 March 2026?
The transitional period provided in the No Action Letter ends on 1 March 2026, and the EBA will issue further guidance, in due time, on the implications for CASPs once that period ends. CySEC Circular C756 (16 February 2026)
Is the national transitional regime to 1 July 2026 an extension of the CBC filing window?
No. The Circular references that national transitional regime by footnote, until 1 July 2026 under Article 143(3) of the MiCA Regulation, as a separate matter from the CBC payment-services application date. CySEC Circular C756 (16 February 2026)
