Joint response to the ESMA consultation on MiCA RTS

by | Dec 15, 2023 | news, Regulation&Taxation | 0 comments

We are pleased to share our response to the consultation on the draft RTS on the content, methodologies, and presentation of sustainability indicators on adverse impacts on the climate and the environment proposed by the European Securities and Markets Authority (ESMA). Lead by Mariana de la Roche-Wills, Anja Blaj, and Adriana Torres the response is a joint effort of INATBA – International Association for Trusted Blockchain Applications and the European Blockchain Association e.V. in collaboration with Adan and the European Crypto Initiative, the response addresses 12 questions covering different aspects from sustainability disclosure under MiCA, to relevant features of consenus mechanisms, and guidance on methodologies and data sources.

Read and download the full response here.

“Overall, our key request was to ensure that the future sustainability indicators are designed to be applicable across all consensus mechanisms. This approach is essential for fostering transparency, comparability, and accountability within the crypto-asset sector. While we can draw inspiration from existing frameworks like CSRD and SFDR, it’s crucial to emphasize that a simple copy-and-paste approach won’t work. We must consider the unique characteristics of blockchain and conduct a thorough feasibility assessment before implementing these indicators. It’s imperative that we develop methodologies that issuers and CASPs can realistically and effectively implement” says Mariana de la Roche-Wills. “The significance of conducting a feasibility study to ascertain the practicality of these regulations in the crypto space is a must. We understand that for any regulation to be effective, it must be implementable and realistic within the crypto industry’s unique ecosystem.”

Thank you to all our partners and contributors for their valuable insights and expertise in particular to our members at INATBA, EBA, Adan and EUCI and to the contributions of the EU Blockchain Observatory and Forum expert panel and the members of the Electronic Money Association