New delegated regulation on RTS! Regulations in liquidity management policy under MiCA

On 3 October 2025, the Commission Delegated Regulation (EU) 2025/1264 of 27 June 2025 was published in the EU Official Journal. It supplements MiCA (EU) 2023/1114 by laying down Regulatory Technical Standards (RTS) that define the minimum contents of liquidity management policies and procedures for certain issuers of asset-referenced tokens (ARTs) and e-money tokens (EMTs). The regulation enters into force on October 23, 2025 (20 days after publication).

Who does the regulation cover?

The RTS apply to: issuers of significant ARTs, electronic money institutions issuing significant EMTs, and- where required by the competent authority- issuers of non-significant ARTs and EMIs issuing non-significant EMTs. Legal basis is MiCA, Article 45(7).

What are the requirements for the RTS?

• Policies and procedures must include robust identification, measurement, management, monitoring and internal reporting of liquidity risk and ensure an adequate level of reserve assets, including under stress; management/board approval and risk-tolerance levels are required.
• Reserve monitoring covers, inter alia: identifying reserve assets, valuation criteria, assessment of concentration and currency-mismatch risks, and techniques to keep the reserve’s value stable relative to referenced assets.
• Intraday liquidity: issuers must maintain mechanisms for intraday liquidity management.
• Early-warning indicators and contingency planning: thresholds for deviations between token/reference-asset values and reserve values, plus actionable responsetools.
• Background RTS: were drafted by EBA in close cooperation with ESMA and underwent public consultation and cost-benefit analysis.

Why are changes so important?

This is a practical, supervisory-grade layer of MiCA: it shifts focus to operational liquidity discipline. Issuers should now audit existing policies, reinforce stress-testing and early-warning playbooks, reduce custodian concentration, and secure formal board approval of updated frameworks.

The new MiCA RTS are now in effect- are you ready?

The new liquidity management requirements for ART and EMT issuers mean more than just updating documents. It is time for a real audit of policies, implementation of warning mechanisms, and approval of procedures by the management board.

Don’t wait for sanctions! Contact us-we will help prepare your organization for its new responsibilities!