In this Article
The Malta Financial Services Authority (“MFSA”) has taken a significant step in the local implementation of the EU’s Markets in Crypto-Assets Regulation (“MiCA”), with the issuance of the new Markets in Crypto-Assets Regulation (“MiCA”). The latter legislative instrument applies to entities governed by the Markets in Crypto-Assets Act (Chapter 647 of the Laws of Malta) (“MiCA Act”), and has been published alongside updates to Chapter 3 of the Financial Institutions Rulebook (“FIR/03”), which regulates Payment Institutions and Electronic Money Institutions. These changes, published on 11th March 2025, are aimed at aligning Malta’s regulatory framework with EU-wide standards and enhancing legal clarity for businesses operating in the digital finance space.
A Regulatory Milestone for Crypto-Asset Service Providers and Token Issuers!
The MiCA Rulebook is intended to operate in parallel with the MiCA Act, MiCA and the accompanying Regulatory and Implementing Technical Standards issued by the European Supervisory Authorities such as ESMA and EBA. These instruments provide the necessary detail and interpretative guidance to ensure consistent application of the MiCA framework across the EU. The newly published MiCA Rulebook outlines the procedures and obligations for obtaining authorisation as a Crypto-Asset Service Provider (“CASP”) or an Issuer of Asset-Referenced Tokens (“ARTs”), as well as the notification process for publishing a crypto-asset whitepaper and the voluntary surrender of a licence. It also includes a non-exhaustive list of applicable regulatory standards and guidelines, together with ongoing compliance requirements for authorised entities under the Act.
In parallel, the MFSA has published updated regulatory reporting templates and guidance documentation, following a consultation process held earlier this year. These tools are intended to streamline reporting obligations for CASPs and reinforce consistency in supervisory engagement.
Updates to the Financial Institutions Rulebook
The amendments under the FIR/03 Rulebook, governs Payment Institutions and Electronic Money Institutions (“EMIs”). These changes are particularly relevant for EMIs that issue Electronic Money Tokens (“EMTs”) and introduce additional regulatory provisions that reflect applicable EU standards.
Key elements of the revised chapter include the formal integration of relevant delegated acts, technical standards, regulations and guidelines affecting EMT issuance. In addition, the updates clarify procedural requirements around outsourcing arrangements and safeguarding measures. Under the new framework, all related communications and documentation must be submitted via the MFSA’s Licence Holder Portal, and notifications regarding planned changes must be submitted at least 60 calendar days in advance.
Immediate Effect and Industry Action
These changes are effective as of 11 March 2025, the date of publication. As the updates serve to implement binding EU law or provide clarification on existing obligations, the MFSA has confirmed that no transitional period will apply.
Entities currently offering, or intending to offer, services falling within the scope of MiCA or the updated FIR/03 should carefully review the new documentation and assess their compliance frameworks accordingly.
The full MiCA Rulebook, together with the revised Financial Institutions Rulebook and supporting material, is available on the MFSA’s official website.
For more information about the MiCA rulebook and the amendments brought about under FIR/03, send us an e-mail on contactmkfintech@kyprianou.com or call +356 9905 6193.
More about MK Fintech Partners Ltd.
Michael Kyprianou Fintech Partners Ltd. is a Maltese company providing services in the FinTech sector. It comprises a team of dedicated experts who provide services such as Legal Advisory, Crypto Licensing, Token Issuers’ Licensing, Investment Services Licensing, and registrations of activities related to Fintech, Crypto, Blockchain & Data Protection, Investment Funds Services & Banking, Company Incorporations, and M&As.
MK Fintech Partners forms part of the Michael Kyprianou Group, a top tier international legal and advisory firm. It has established an enviable reputation as a broad-based legal practice over the years. Mainly by keeping at heart its principle to always exceed its clients’ expectations. MK has grown to become one of the largest law firms in Cyprus with offices in Nicosia, Limassol and Paphos. The MK Group’s international presence also includes fully-fledged offices in Greece (Athens and Thessaloniki), Malta (Birkirkara), Ukraine (Kiev), the United Arab Emirates (Dubai), United Kingdom (London), Israel (Tel Aviv), and Germany (Frankfurt).
The content of this article is valid at the date of its first publication. It intends to provide a general guide to the subject matter and does not constitute legal advice. We recommend that you seek professional advice on a specific matter before acting on any information you read. For further information, contact us at MK Fintech Partners via email at contactmkfintech@kyprianou.com or by telephone +356 2016 1010.
