ESMA_QA_2933
Topic
Crypto-Asset Service Provider (CASP)
02/10/2026
Subject Matter
Technical roles of non-EU group entities in transaction signing and signing policies
Question
1. Can a non-EU (group) entity co-sign transactions without being considered to exercise control over EU client assets or provide custody?

2. Can a non-EU (group) entity alter signing policies without being considered to exercise control over EU client assets or provide custody?
Level 1 Regulation
MiCA
ESMA_QA_2932
Topic
Crypto-Asset Service Provider (CASP)
01/10/2026
Subject Matter
Transient exposure of EU client crypto-assets in a non-EU hot wallet during deposits, withdrawals and settlement
Question
In the context of in/out transfers (deposits/withdrawals) from an EU authorised CASP, can assets from EU clients temporarily be held in a (hot) wallet at an entity not authorised as a CASP under MiCA? Under what conditions, if any, would the temporary presence of EU client crypto-assets in that wallet be considered a purely technical/transient transfer step rather than custody, administration or transfer services being provided by the non-authorised entity?
Level 1 Regulation
MiCA
ESMA_QA_2926
Topic
CSD questions - Requirements for CSD services (reconciliation measures, asset segregation, settlement finality, participant default rules and procedures)
21/09/2026
Subject Matter
CSDs settlement assets
Question
Under the current CSDR framework, are CSDs allowed to settle in: a) tokenised central bank money, b) tokenised commercial bank money, and c) e-money tokens?
Level 1 Regulation
Central Securities Depositories Regulation (CSDR) Regulation (EU) No 909/2014- PTR- CSDR
ESMA_QA_2925
Topic
CSD questions - Authorisation of CSDs
21/09/2026
Subject Matter
Integration of DLT settlement solution in CSD security settlement system
Question
Does the integration of DLT components, or more specifically, of a DLT settlement solution, into a traditional securities settlement system operated by a CSD require the authorisation of a new securities settlement system in accordance with Article 19(1)(c) of CSDR?
Level 1 Regulation
Central Securities Depositories Regulation (CSDR) Regulation (EU) No 909/2014- PTR- CSDR
ESMA_QA_2924
Topic
General questions - Book-entry form
21/09/2026
Subject Matter
DLT and book-entry form definition
Question
Article 3 of CSDR refers to the requirement for transferable securities to be recorded in book-entry form. Does the use of distributed ledger technology (DLT) meet the definition of book-entry form? More broadly, can CSDs use DLT to provide CSD services under CSDR?
Level 1 Regulation
Central Securities Depositories Regulation (CSDR) Regulation (EU) No 909/2014- PTR- CSDR