ABBL response - MiCA ESAs - Classification of CA - Final.pdf

Here are the key points summarized:

Q2: Comments on the template

• The template should be more detailed and specify the length of each part.
• The fields relating to explanations as to regulatory status should be clearer and proportionate to the complexity of the crypto-asset.
• The template should include an assessment for hybrid crypto-assets.
• The flow chart contains errors regarding the choice between EMT and ART, and should be updated.

Q3: Comments on the standardised test

• The standardised test should incorporate an assessment for hybrid crypto-assets.
• The flow chart should be updated to better align with the answers Yes/No.
• The wording of the question "What is the technology used for this purpose" should be changed to make it close-ended.

Q4: Comments on the standardised test

• None provided.