EMT issuance: bank segregated account

Q&A on EMT issuance: bank segregated account.

Authority	EBA
Q&A ID	EBA_QA_2025_7591
Status	Rejected
Published	11 November 2025
Legal basis	Articles 54, 58 MiCA
Source	EBA Q&A

Question

Do banks (credit institutions) need to maintain a segregated account to safeguard the proceeds from e-money token issuance under MiCA?

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Answer

Rejected. The issue is already addressed in the existing regulatory framework — segregated account requirements for banks fall under CRR/CRD, not MiCAR. Addressing it through the Q&A process would put into doubt the existing legal framework.

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Source: EBA Single Rulebook Q&A