Adan Releases Its Position on the MISP

The Adan proposes several key changes to improve the DLT Pilot Regime ( DLTPR) and ensure the European Union’s global competitiveness:

• Rapidly implement targeted adjustments to the current pilot program, while continuing in-depth discussions on the MISP. Any delay risks diverting global liquidity to more agile markets.

• Extend the DLT program to ensure long-term regulatory clarity.

• Welcome the expansion of the scope of eligible assets to include all financial instruments.

• Remove the current cap or, failing that, raise it to 500 billion euros, while establishing flexible mechanisms to adjust these thresholds as market conditions evolve.

• Enable EMT payments by allowing:

  • all EMTs authorized under MiCA (not just significant EMTs);

  • EMT accounts that are both loans (and not just pre-financed);

  • electronic money institutions (and not just credit institutions) to settle EMT transactions.

• Allow digital asset service providers (CASP) authorized under MiCA to operate DLT trading platforms as well as integrated trading and settlement systems.

• Simplified regime vs. standard regime: streamline the system across the board; allow approved entities to remain under the standard regime without being automatically switched to the simplified regime; and ease the requirements associated with switching from the simplified regime to the standard regime.