1 min readWarningEBA reporting framework 4.2Updated 10 November 2026

Average: transfers between non-custodial wallets per day cannot be less than transactions between non-custodial wallets per day (Q 04.03.a, EBA rule v22934_m)

A warning in the asset-referenced and e-money tokens return (MiCA), on template Q 04.03.a, s_04.03: transactions and transfers per day between non-custodial wallets - average.

The rule in plain words

Transfers between non-custodial wallets per day - average cannot be less than transactions between non-custodial wallets per day - average.

All the values are in the number column (0010) of Q 04.03.a.

How the Line4 Check report words itShow

Word for word as the report shows it when the rule fails.

Transfers between non-custodial wallets per day - average >= Transactions between non-custodial wallets per day - average

What to do if your filing fails it

  1. 01Open the template below and find the cells the rule reads.
  2. 02Compare the values in your file. If the first is smaller than it may be, one of them is wrong: check both before you change either.
  3. 03EBA allows a small rounding difference, worked out from the decimals each value is reported with.
  4. 04It runs only when your filing indicators mark Q 04.03 as reported.
  5. 05This is a warning. It does not stop the filing on its own, but your authority may ask you to explain it.

The cells it reads

S_04.03: transactions and transfers per day between non-custodial wallets - average (Q 04.03.a)

Rows

  • 0010Transactions between non-custodial wallets per day - average
  • 0020Transfers between non-custodial wallets per day - average

Column

  • 0010Number

A worked example

The first of its checks, with simple numbers.

Illustrative values
Transfers between non-custodial wallets per day - average1,200
What the rule then expects

Transactions between non-custodial wallets per day - average can then be at most 1,200.

1,200Passes
1,300Fails

A file that reports 1,200 passes. One that reports 1,300 fails, by 100.

The numbers are illustrative, reported to the unit, so the rounding tolerance does not change the result.

Show the rule as writtenShow

EBA's formula. Cells are written as {template, row, column, sheet}.

{Q_04.03.a,r0020,c0010,} >= {Q_04.03.a,r0010,c0010,}

Every MiCA rule, by template

Checks like this one, run at the point of submission, are the first step to real-time supervision.