On 3 October 2025, there was published in the Official Journal of the EU (OJ), Commission Delegated Regulation (EU) 2025/1264 of 27 June 2025 supplementing the Regulation on markets in crypto assets (MiCA) with regard to regulatory technical standards (RTS) specifying the minimum contents of the liquidity management policy and procedures for certain issuers of asset-referenced tokens and e-money tokens.

The RTS under Article 36(4) of MiCA establish the minimum amount of deposits in each official currency referenced, including also for the cases of significant tokens under Article 45(7) for consistency reasons. Within the specification of the minimum contents of the liquidity management policy and procedures, the RTS set out procedures for identifying, measuring and managing liquidity risk. Furthermore, they envisage a contingency policy and mitigation tools and outline minimum aspects of liquidity stress testing.

The Delegated Regulation enters into force on the twentieth day following its publication in the OJ (23 October 2025).

Photo of Nikolai de Koning Nikolai de Koning

Nikolai de Koning is a financial services lawyer (advocaat) based in Amsterdam. Nikolai is experienced in financial services and banking law, as well as in data privacy (protection). He is experienced in advising on regulatory and compliance aspects relevant to financial…

Nikolai de Koning is a financial services lawyer (advocaat) based in Amsterdam. Nikolai is experienced in financial services and banking law, as well as in data privacy (protection). He is experienced in advising on regulatory and compliance aspects relevant to financial institutions, such as insurance companies, investment firms, clearing institutions and central counterparties. Nikolai also advises on Dutch licence and notification requirements and he assists companies in their licence or notification processes with the Dutch financial regulators. He also specialises in privacy issues arising out of online products, data protection and e-commerce.