The EACB welcomed the possibility to comment on EBA RTS for calculating and aggregating crypto asset exposures, under Article 501d(5) of CRR3. We support the objective of these draft RTS to further specify technical elements that ensure a sound prudential treatment of crypto-asset exposures in the EU, taking into consideration the Basel standard on the prudential treatment of crypto-asset exposures.
The Secretariat underlines the importance to take into account international developments and the implementation of regulatory frameworks dedicated to crypto-exposures in other major economies such as the US and the UK. It is key to avoid any gold plating of international standards that would lead to a tilting of the global level playing field. Overly stringent requirements exceeding the Basel standards may hinder EU financial institutions from advancing key initiatives/scaling the learning curve, thereby impeding technological innovation in distributed ledger technology within the European financial sector.
Moreover, given the possible overlap between the finalisation of the EBA regime and the launch of the Commission’s own reflection on the matter, it would be essential to ensure that final rules are aligned with the transitional rules as much as possible. Market participants will indeed allocate time and resources to comprehend and implement these interim rules, including adapting their infrastructure.