EU payment autonomy for agentic payments: FNA’s response to the MiCA review
A firm in one Member State buys a small piece of work from a supplier in another. It wants to pay in euro e-money tokens once the work is delivered. If the two firms hold their tokens with different providers, and those providers have no arrangement with each other, the firms may need to use the same provider or add a conversion step. For a small payment, that extra coordination can make the transaction uneconomic.
Europe has rules for issuing euro e-money tokens (EMTs). It has no framework that lets several regulated providers make them usable as one payment arrangement. We raised this on 30 September 2026 in our response to the European Commission's consultation on the review of the Markets in Crypto-Assets Regulation, (MiCA). Our full position is in the position paper.
We encourage the Commission to consider an opt-in framework for these arrangements, in two steps. The first is shared coordination infrastructure: a model rulebook, open standards for message formats and for letting a customer of one provider pay a customer of another, common assurance and reporting interfaces, and published participation criteria. This needs no new legislation. The second, only if voluntary coordination proves insufficient, is a narrow statutory route to recognise or designate arrangements that meet defined criteria.
Settlement in central bank money is already available. Since 21 September 2026, the Eurosystem's Pontes service has offered settlement in central bank money for transactions recorded on distributed ledgers, and electronic money institutions can qualify to use it. Positions between EMT providers can therefore settle in central bank money, as retail payment systems' positions already do. What is missing is the arrangement that uses that settlement: a common rulebook, clear responsibilities between providers, and a way for supervisors to oversee the arrangement as a whole.
Fraud and scams need controls across providers. A single issuer or wallet provider holds data only on its own part of a fraudulent payment chain. Tracing funds, freezing suspected proceeds, identifying mule accounts, and scoring transactions before execution all need to work across providers. These cross-provider controls need a legal basis in Union law and a clear allocation of fraud losses between sending and receiving providers.
Software will increasingly initiate payments for firms under authority granted in advance. These agentic payments have the same problem between providers, and one more. We know of no standard, interoperable model for authority that is variable in amount, bounded in scope, and revocable by the payer. The paper sets out what such a model should specify. The model applies to the regulated institution that issues and enforces the mandate, and creates no new regulated category for software. Without a euro arrangement of this kind, firms may choose non-euro instruments and non-European infrastructure for these payments.
We do not propose mandatory acceptance, changes to central bank access or prudential standards, or privileged treatment of any provider, model, or architecture. Each issuer keeps its own liabilities.
Disclosure of interest: FNA develops supervisory, analytical, and fraud-detection technology for financial authorities. It also works on Raha, a euro scheme for agentic payments in tokenised money (e-money tokens and tokenised deposits), and Sinetti, a trust layer for agentic payments.
