ROMANIA Trends and Developments Contributed by: Alexandru Stanescu, Simina Negulescu, Stefan Gheorghe and Ioana Vișan, Lexters
• RWA and tokenisation platforms: real-time inves- tor eligibility checks (accredited status, jurisdiction, corporate data) pulled from wallet attestations at the point of investment, replacing manual docu- ment cycles that delay token offerings by days or weeks. • DeFi and Web3 infrastructure providers: protocols can gate access to pools or services using wallet- based verification as a compliance layer, without full deanonymisation; pseudonymous access remains where no legal identification requirement exists. • Blockchain-based SaaS and professional services: cross-border credential verification (eg, bar admis- sion, trade licences) without bilateral data-sharing agreements, including offline. Private businesses interact with the wallet as regis- tered relying parties; the wallet itself is issued by mem- ber states. Registration requires declaring the specific data fields requested, and relying parties may not go beyond what was declared. Data minimisation is hard- coded: wallet-derived data cannot be combined with other datasets without explicit consent, data protec- tion impact assessments (DPIAs) are required before deployment, and incident response must align with the 24-hour breach notification window. Contracts with wallet infrastructure providers and attestation intermediaries should cover purpose limi- tation, breach notification, a prohibition on combin- ing wallet data with other sources, and continuity-of- service provisions. Businesses should begin now by mapping onboarding flows and identifying the mini- mum attribute set needed per service. Key Regulatory Developments to Monitor for Romanian Blockchain Businesses (2026-2027) The framework above is largely in place, but several legislative threads remain open. Their resolution over the next 12 to 18 months will frame the operating envi- ronment for Romanian blockchain businesses. Key items to track are as follows. • The Romanian MiCA GEO Draft should be moni- tored through to final adoption; upon publication,
the ASF and BNR must issue implementing regula- tions within 30 days. The secondary rules will set the practical requirements for authorisation, techni- cal conditions and sanctions. • The PSD3/Payment Services Regulation (PSR) package will be very relevant for crypto-payment models. This is especially important for projects involving stablecoins, cards, merchant payments and consumer wallets. One key open question is how EMT-related services will be treated under the future payments framework. • The AMLR will require many crypto firms to update their AML procedures before July 2027. This may affect onboarding, screening, outsourcing, report- ing and record-keeping policies. • Consumer protection will also become more impor- tant. The Consumer Credit Directive must be trans- posed into national law by 20 November 2026, tightening rules on digital and small-value credit – including blockchain-based microcredit products, which may simultaneously trigger consumer credit, non-banking financial institution, crowdfunding, AML and payments rules. • In addition to the above, AI agents and blockchain payments are worth watching as an emerging top- ic. Autonomous software agents increasingly need an instant, programmatic, cross-border settlement layer, and stablecoins may offer a practical rail for small, automated payments between agents, plat- forms, APIs and digital services. Automation does not place these flows outside regulation: depend- ing on the structure, payment services, e-money, AML, consumer protection, outsourcing and liabil- ity rules may still apply. Romania in 2026 offers a defined legal perimeter, accessible competent authorities and a set of struc- tures – MiCA authorisation, the EMI-CASP split for payments, SPV-anchored tokenisation, ECSPR- aligned crowdfunding – that operators can build on with confidence. For a more detailed analysis of Romania’s legal framework for blockchain and crypto- assets – including authorisation pathways, AML obli- gations, tax treatment, payments rules and tokenisa- tion – see the Romania Law and Practice chapter in this guide.
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