Background:  

According to the Foreigners Act in Slovenia, a third-country national wishing to reside in Slovenia must demonstrate sufficient means of subsistence for the issuance of a residence permit. Slovene authorities encountered new cases where applicants attempted to demonstrate sufficient financial resources using crypto assets, ranging from volatile cryptocurrencies (e.g. Ethereum) to fiat-pegged stablecoins (e.g. USDC). To establish clear national rules, the Slovenian National Contact Point to the EMN launched this query to gather information on how other countries address cryptocurrencies in residence permit procedures. 

Respondents:  

25 EMN Member and Observer Countries (including BE) provided a public answer to this ad hoc query. 

Findings:  

A preliminary analysis of the results of the ad hoc query shows that: 

• The vast majority of responding EMN member and observer countries do not accept cryptocurrency assets as proof of sufficient means of subsistence in residence permit procedures. In most countries, crypto assets are generally not accepted as valid proof on their own. Key reasons cited include a lack of legal tender or official currency status, price volatility and unpredictable future value, inability to cover daily living expenses directly in everyday transactions, and the absence of verification mechanisms or statutory inclusion in official lists of required documentation. 
   
• Only a few EMN members accept cryptocurrency assets under specific, strict conditions, with varying approaches to asset categorisation. NL accepts crypto assets in the same manner as other financial assets provided they are declared to tax authorities, while FI accepts cryptocurrencies if they can be liquidated immediately into euros. HU accepts cryptocurrency to a limited extent as secondary evidence, or as sole proof for short-term visa applications by major investors. Furthermore, FI explicitly differentiates between categories, accepting stable, well-known cryptocurrencies while rejecting highly volatile ones, whereas NL and HU do not differentiate between categories when assessing admissibility. 
   
• Volatility, liquidability, ownership verification, and tax compliance represent the main challenges identified by EMN member countries. FI notes the difficulty caseworkers face in assessing how quickly a cryptocurrency can be liquidated in practice, while SE highlights potential obstacles in proving that crypto holdings actually belong to and remain available to the applicant over time. EE, HU, and NL emphasise that crypto assets or income derived from them must be properly declared, taxed, or substantiated in euros. 
   
• Specific good practices and evaluation methodologies were highlighted by EMN member countries. FI identified CoinMarketCap as a reference source to evaluate volatility over the past 12 months, valuing assets at their lowest valuation level over the past year to mitigate financial risk. Other EMN Members (such as AT, DE, PT) advise applicants as a practical rule to convert crypto holdings into euros deposited in a recognised bank account prior to applying. 

For further details, please read the compilation of answers attached above.