I would strongly assume that the EMI license is about something different and does not enforce that your digital cash needs to be re-imbursable if you lost it.
There is already precedent of cash cards like GeldKarte which also were non-reimbursable if you lost the physical card, so at least BaFin would allow something like that, but I don't know if that predated the EMI rules.
Are you sure they didn't just mean the requirement that they have to keep the capital around (at least in significant parts) to cash out any tokens they emit?
There is already precedent of cash cards like GeldKarte which also were non-reimbursable if you lost the physical card, so at least BaFin would allow something like that, but I don't know if that predated the EMI rules.
Are you sure they didn't just mean the requirement that they have to keep the capital around (at least in significant parts) to cash out any tokens they emit?