Applicability of DORA and TFR requirements to VASPs

Do the requirements of the Digital Operational Resilience Act (DORA) and the Transfer of Funds Regulation (TFR) apply to Virtual Asset Service Providers (VASPs) that are not classified as Crypto-Asset Service Providers (CASPs) under the Markets in Crypto-Assets Regulation (MiCAR) as of December 30, 2024 and are benefiting from the MiCAR transition period?

MiCAR's implementation on December 30, 2024, necessitates clarity on whether DORA and TFR obligations extend to VASPs not classified as CASPs. This is crucial for regulatory compliance and operational integrity. Guidance is needed on how these regulations interact with existing frameworks, particularly concerning the distinct AML/CFT classifications. Following MiCAR, CASPs will be designated as financial institutions under the revised AMLD (Directive (EU) 2015/849), while VASPs remain obliged entities under the existing AMLD. This fundamental difference in classification significantly impacts the scope of DORA and TFR applicability. This inquiry focuses on VASPs operating within the MiCA transitional period.   It should be also noted the distinct AML/CFT classifications - that CASPs will be classified as financial institutions under the amended AMLD (Directive (EU) 2015/849), while VASPs will remain obliged entities under the current AMLD.