New challenges in crypto-assets regulation in Romania: The impact of GEO 10/2025

The entry into force of this ordinance marks an important step in the regulation of crypto-assets in Romania, also representing the materialization of a legislative process that began with the presentation of the draft GEO, which sparked extensive debates within this sector.

The main legal novelties it brings are:

• Reconfiguration of crypto-asset regulation: a unified status for providers

A fundamental change brought about by GEO 10/2025 is the adjustment of the old definitions used in Law 129/2019 for operators in the crypto industry to align with the requirements of MiCA. Furthermore, crypto-asset service providers are assimilated to financial institutions under Law 129/2019. This change in status brings a series of specific obligations that crypto-asset service providers must comply with from the perspective of anti-money laundering and anti-terrorism financing legislation.

• Repeal of Article 301: Legislative gap or preface to a reform?

One of the most controversial changes is the repeal of Article 301 from Law 129/2019, which regulated a so-called authorization providers for CASPs.

This article established the obligation to obtain authorization and/or registration at the national level. Through GEO 10/2025, this authorization requirement for CASPs is completely removed. However, they become reporting entities under Law 129/2019, due to the newly granted status of financial institutions.

It must be emphasized that there is still no clear authorization or registration mechanism at the national level, despite the specific references in GEO 10/2025 to the authorization procedure outlined by MiCA (which includes certain provisions related to a so-called grandfathering period for the new authorizations regime).

• Mandatory single point of contact for non-resident CASPs

For CASPs authorized in other EU states, GEO 10/2025 introduces the obligation to designate a single point of contact in Romania.

This single point of contact will facilitate communication with Romanian authorities and ensure compliance with national anti-money laundering requirements. 

It is worth noting that GEO 10/2025 grants explicit responsibilities to the National Bank of Romania (BNR) and the Financial Supervisory Authority (ASF) for the regulation, supervision, and control of crypto-asset service providers' activities.

The changes introduced by this new legislative act are substantial, not only by clarifying the obligations of crypto service providers and strengthening anti-money laundering measures but also by raising new questions regarding the practical implementation of compliance requirements and supervisory mechanisms. A swift understanding of their impact can become a competitive advantage for the entities concerned.