OpenLobby.EU
Explore

International Association for Trusted Blockchain Applications

INATBA

The objective of the Association is to enhance trust and innovation in blockchainand other distributed ledger technology through the promotion of guidelines and specifications for interoperable blockchain and other distributed ledger technology infrastructures and applications that accord with the relevant principles of EU and international law, meet the highest standards of cybersecurity, privacy, and energy efficiency, and where liability and responsibility are clearly established through transparent governance models.

Lobbying Activity

Response to European Innovation Act

3 Oct 2025

The International Association for Trusted Blockchain Applications (INATBA) welcomes the European Innovation Act (EIA) as a critical step toward strengthening Europes competitiveness and technological sovereignty. INATBA represents Europes blockchain and distributed ledger technology (DLT) ecosystem, bringing together innovators, enterprises, policymakers, and civil society. With a strong track record in sustainability, standardisation, and innovation policy, we serve as a trusted intermediary between public and private stakeholders. With global membership across continents, INATBA brings an international perspective that can help align the EIA with emerging global standards and competitiveness imperatives. Recent international discussions on sustainable development finance have underlined that the worlds challenge is not a lack of capital but its misallocation, with debt service often outweighing investment in health, education and SDG-relevant sectors. They also stress the urgency of mobilising all sources of funding, public and private, and reforming financial flows to support inclusive, sustainable growth. INATBA believes the EIA can translate this global call into Europes innovation policy by embedding interoperable, tokenised financing tools that channel capital into SDG-aligned innovation and infrastructure. As the Commission prepares this flagship initiative, we believe that the Act should fully embrace the role of emerging technologies such as DLT, artificial intelligence, and the Internet of Things as horizontal enablers of innovation across sectors. The following recommendations outline how the EIA can unlock innovation while ensuring that it contributes to Europes climate, social, and economic objectives. More information is in the attached document.
Read full response

Response to Rules and conditions for the establishment and the operation of the interoperability regulatory sandboxes

13 Mar 2025

The International Association for Trusted Blockchain Applications (INATBA) welcomes the European Commission's initiative outlining the rules and conditions for the set-up and operation of Interoperability Regulatory Sandboxes, established under Regulation (EU) 2024/903. We would like to highlight two key concerns that could impact the effectiveness of the initiative: The need for greater private sector involvement Excessive access requirements that may stifle innovation #1: The Need for Greater Private Sector Involvement The proposal adopts a predominantly top-down approach where the establishment and governance of interoperability regulatory sandboxes are restricted to public sector bodies and Union entities. However, for the sandboxes to truly foster innovation, private sector actors, including SMEs, start-ups, and industry stakeholders, should be granted a more proactive role in initiating and co-developing these sandboxes. Article 3 (Eligibility for the establishment of interoperability regulatory sandboxes) of the proposal: Article 3(1) and (2) restrict the establishment of interoperability regulatory sandboxes to public sector bodies or Union entities, limiting private sector involvement in initiating and shaping these environments. Key Recommendations: Allow private sector entities to participate in initiating and coordinating sandboxes alongside public sector bodies. Introduce mechanisms for public-private partnerships within the governance framework of interoperability regulatory sandboxes. Ensure that regulatory sandboxes remain open to private-sector-led projects that address interoperability challenges faced by both government institutions and industry stakeholders. To strengthen the role of private sector participation, we propose specifying potential collaboration models thanks to which this could be achieved. Examples could include a multi-stakeholder advisory board involving private sector representatives in sandbox governance, a co-development framework that allows private entities to propose and co-lead sandbox initiatives with public bodies, or prioritization of industry-driven regulatory challenges within the sandbox framework to ensure practical, real-world relevance. #2: Access Requirements and the Risk of Hindering Innovation One of the core benefits of regulatory sandboxes is their role in allowing entities to experiment with and test innovative solutions in a controlled environment. However, the current proposal imposes stringent eligibility criteria that require participants to be fully compliant with existing regulations before entering the sandbox. This contradicts the fundamental purpose of a regulatory sandbox, which should provide a space for participants to explore, iterate, and refine their solutions while engaging in dialogue with regulators. This issue is particularly exemplified in Article 10 (Admission of participants to regulatory sandbox projects) and Article 11 (General rights and obligations of participants in regulatory sandbox projects) of the proposal: Article 10(1) and (2) outlines that participants (such as GovTech actors, SMEs, or other private sector innovators) can only join an already established sandbox project if they meet pre-set conditions defined by the regulatory sandbox coordinators. Article 11(1)(c) further requires that participants ensure compliance with all applicable legal requirements and obtain necessary authorizations before starting a projectpotentially excluding innovative solutions that are precisely in need of regulatory testing. These provisions impose an unnecessarily high compliance burden for entry into the sandbox, contradicting the principle that regulatory sandboxes should provide a space to experiment and test innovations rather than requiring full compliance upfront. This effectively prevents participants who might benefit most from sandbox participation from entering in the first place. (More text in the attached document)
Read full response

Response to Strengthening existing rules and expanding exchange of information framework in the field of taxation (DAC8)

23 Mar 2023

DAC8: Industry Position Paper The following are our preliminary comments regarding the European Commissions proposal for the 8th amendment to the Directive of Administrative Cooperation (DAC8). We would be delighted to further elaborate on the various aspects of the proposal, as appropriate. 1) Introductory Remarks Overall, we acknowledge that in the field of crypto-assets there is a need for increased tax information transparency. We thus welcome the Commission's decision to extend the scope of the existing DAC regime to also cover the exchange of information on crypto-assets. Regulating the legislative field of crypto tax reporting by means of a Directive will, at least to some extent, reduce fragmentation across EU Member States as well as curb the increase in costs and the compliance burden for Crypto Asset Service Providers (CASPs). Also, we strongly support the Commissions efforts to ensure consistency between OECD and EU rules in order to increase the effectiveness of information exchange while reducing administrative burdens. A Directive in line with the OECD's Crypto Asset Reporting Framework (CARF) is another milestone towards the desired regulation of the industry, promoting its sustained growth and adoption. Ultimately, we acknowledge the principle that crypto tax reporting should no longer be the sole responsibility of individuals, but should also be dealt with, or at least supplemented by, CASPs. Yet this industry is still in its infancy and the dynamics of the market lead to a rapidly changing landscape, both technically and legally. This presents a rather challenging situation for CASPs, who should therefore not be burdened with excessive or practically unimplementable reporting requirements. Altogether, we stress that CASPs, or more generally crypto service providers and operators, should not be treated more adversely or be subject to a greater compliance burden than similarly situated financial service providers. 2) Main Comments Overall, we want to highlight the following points of concern (not ranked in any specific order): a. while CASPs will be required to assess and classify reportable crypto-assets on a case-by-case kind basis, the proposal does not provide clear guidance in this regard; b. the inclusion of staking and lending as Crypto-Asset Services and the related impact on the scope of the term 'Crypto-Asset Operator' (CAO) is not only alien to CARF, but also goes beyond what has been agreed under the EU-Regulation on Markets in Crypto-Assets (MiCA), leading to an incoherent expansion of the scope of the regulatory perimeter and thus potentially disadvantaging the EU single market (gold plating); c. the freezing of accounts deemed to be non-compliant is not a requirement in CARF and goes beyond the requirements that apply to traditional financial institutions, thus thwarting the principle of equal treatment (i.e. horizontal equity); d. the practical implementation needs to respect data privacy and be guided by industry best practices in terms of sufficient data security and data protection; e. while the system of a standardized TIN would greatly facilitate the implementation of the DAC8, its timely introduction seems very ambitious from today's perspective; f. recognizing the significant implementation challenges facing CASPs, we would support the introduction of an interim penalty abatement regime; g. despite the rather short implementation period, the proposal does not contain any concrete standards on the exact implementation of the reporting standards (in particular, there is a lack of provisions that ensure a minimum degree of the transmitted data quality).
Read full response

Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur)

25 Apr 2022 · European Digital Identity proposal (eID)

Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur) and LA POSTE

11 Mar 2022 · European Digital Identity proposal (eID)

Response to Europe’s digital decade: 2030 digital targets

9 Mar 2021

The Education Working Group of INATBA (International Association of Trusted Blockchain Applications) is committed to identify and provide recommendations on the definition and standardization of blockchain education, both on an academic and professional level. We hereby support the Commission initiative on a Europe’s digital decade: 2030 digital targets and wish to advise on the way the EU should build capacities through digital education and skills. The Working Group acknowledges a lack of digital education on all layers of European society. Therefore, we attach the INATBA Education Working Group paper Blockchain Education: A Prerequisite for Socio-Economic and Technological Advancement, which aims at describing the current state of industry digitalisation, identifying the target groups that are most urgently in need of Blockchain education and proposing components of a Blockchain curriculum. The paper also integrates a chapter addressing educational targets and a proposal for a Blockchain curriculum. Moreover, the Working Group would like to highlight a number of areas to be addressed by the “4 dimensions” listed in the Roadmap as objectives of the common digital targets. First, prior to delivering digital education, we point out the need for standardisation of terms within the digital community with the aim to reach an agreement on their respective definitions. Second, when delivering digital education, we suggest adopting an interdisciplinary approach, which also takes into account the model of t-shaped person (as understood by McKinsey who also coined the term like David Guest and Tim Brown in the early 2000): We suggest looking for students that are able to discuss matters across the whole process, flexible for change if required and able to learn quickly and adopt new things. Third, we would like to point out the importance of choosing the right way to deliver content. In the context of a pandemic situation, educational content has to be adapted to the way we are delivering education, which is based on the use of new digital technologies and platforms. In addition to this, we see public and private collaborations as essential to scale up how we deliver educational content. Finally, we believe that the socio-economic organisational and infrastructural future is decentralised as it is an individual-centered model of education. The transition from a centralised towards a decentralised socio-economic setting requires supporting legislation and regulation that integrates, supports and fosters the principles of decentralisation. The paradigm shift from a centralised towards a decentralised society, economy and mindset will require huge cognitive efforts from the societal and economic actors. The legislation and regulation needs to take an enabling position in order to unleash the potential of decentralised socio-economic models and unleash its economic power. The creative economic power and the organisational and technological resilience of open decentralised networks is an indispensable ingredient for the socio-economic international positioning of the EU. The public permissionless version of Blockchain is the technological infrastructure that enables or unleashes the full innovative potential of frictionless free transactions, collaboration and organisation. The Digital Roadmap for the EU needs to embrace these basic principles, supporting infrastructure and enabling legislation and regulation in order to allow itself to reach the highest possible capacity of its economic global positioning. The “legacy legislation and regulation” for the organisation of society, economy and business is based on centralised models that don't support the new decentralised paradigm shift. Hence, a fundamental and urgent necessity in the EU’s digital roadmap consists in creating from scratch the socio-economic organisational legislation that integrates the decentralisation principles as a starting point.
Read full response

Response to European Interoperability Framework (EIF) evaluation and EU governments interoperability strategy

12 Nov 2020

The Interoperability Working Group of INATBA gathers expertise from a diverse range of stakeholders, which welcome the revision and evaluation of the EIF and under the broader scope of the ISA2 Programme. Interoperability has never been as important as during this worldwide pandemic. The EIF is essential in providing the right instruments for blockchain to be an enabler during the current digital revolution. INATBA notes that many different applications fall within the scope of the EIF, specifically in regard to contactless payments, contact tracing and proof of location. For the EIF to be successful, there is the need to have more awareness of the currently available tools for interoperable solutions provided by the ISA2 Programme. INATBA members have vast experience using the following tools: Galileo, EGNOS, EIRA (Gaia X Project), TOOP based on the once-only principle, the Once Only Initiative: Towards Cross-Border Connectivity. Moreover, technical experimentation, training and support are needed when these tools are offered through open source models. As a unique focal point between the world of the industry, policy making and academy, INATBA is a platform which facilitates public private exchange and calls for the EU to create a joint project to accelerate the EIF leveraging INATBA’s platform. The EIF includes 47 Recommendations, which follow 12 interoperability principles, that have the function to guide public and private parties in interoperability actions. Due to the non binding character of such principles European Member States do not implement the same recommendations at national level. This leads to fragmentation in the different levels of interoperability among the different member states. Recognising the consequences of such risks, INATBA proposes to convene all governments and stakeholders to foster the adoption of such guidelines and their transposition into national law. Therefore, on the one hand INATBA requests more binding instruments or standards to facilitate interoperability solutions across member states. On the other hand, INATBA further requests to include specific reference to interoperability between blockchains. INATBA calls for an immediate alignment of the 5 interoperability layers included by the EIF (Interoperability governance, Organisational, Integrated public service governance, Semantic interoperability, Legal interoperability, Technical interoperability) with those available in the WEF Toolkit (business model, platform, infrastructure). This will enable businesses to have consistent guidelines for interoperability, encouragement engagement and provide momentum for Europe to establish itself as a leading player for the benefit of the European Industry and European Citizens Authors: The co-chairs of the Interoperability Working Group at INATBA and the INATBA Executive Director Marc Taverner.
Read full response