On October 15, 2024, Adan submitted its comments on the European Banking Authority's (EBA) public consultation regarding Guidelines on templates to assist competent authorities in supervising issuers of ARTs and EMTs, under Regulation (EU) 2023/1114. This consultation aims to address data gaps that could hinder the supervision of issuers. Adan thanks the EBA for the opportunity to contribute to this important discussion.

Adan and its members welcome this initiative while highlighting several key concerns:

Confidentiality of crypto-asset holders: Adan raises concerns about the requirement to report nominative information of holders, which poses risks to privacy and security.
Business confidentiality: The transmission of sensitive data, including the distinction between retail and professional users, could create disproportionate competitive advantages for some issuers.
Harmonization of reporting obligations: The proliferation of reporting templates increases the compliance burden for CASPs and issuers, raising the risk of errors.
Adan calls for adjustments that would preserve the confidentiality of holders while ensuring effective supervision. Among its proposals, Adan recommends focusing on the aggregated number of holders without disclosing individual identities. Alternatively, Adan proposes a solution based on the CONCAT standard, combined with SHA-256 cryptography, to pseudonymize holder data. This would allow CASPs to report data without revealing clients' names, while enabling issuers to identify holders without duplicates, all while safeguarding privacy through encryption.

Adan would like to extend its gratitude to all contributors involved in developing this response, including key stakeholders such as Binance, Circle, Coinhouse, Deloitte, Kramer Levin, Orwl, and SG Forge, for their valuable input. We appreciate the European Blockchain Association for backing our our proposal and supporting our response