MiCA Regulation

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Q: Are non-custodial wallets regulated under MiCA?
A: No. Only the custody and management of crypto-assets on behalf of third parties is regulated under MiCA. Non-custodial wallets allow users to store their own private keys and are therefore not regulated under MiCA.

In addition, the €BACH governance token falls under the Utility Token definition.

Utility token
‘a type of crypto-asset that is only intended to provide access to a good or a service supplied by its issuer’

A good source.