Stablecoins Under MiCA: E-Money Tokens, Issuer Duties, and the Payments Licence Question

Stablecoins were MiCA's first regulated product: the rules for issuers have applied since June 2024, six months before the licensing regime for crypto-asset service providers. Two years later, the market has sorted itself along those rules — non-compliant tokens have disappeared from regulated EU platforms, banks are launching euro stablecoins, and a second licensing question has emerged for everyone who moves them.

MiCA distinguishes two types of stablecoin. Asset-referenced tokens (ARTs) reference a basket of values or assets. E-money tokens (EMTs) reference a single official currency — the euro stablecoin is an EMT. For the payments and fintech world, EMTs are the relevant category, and they are regulated as what they economically are: electronic money on a blockchain.

Who May Issue — and on What Terms

• Authorisation: only credit institutions and e-money institutions may issue EMTs, after notifying a crypto-asset white paper to their supervisor.
• Redemption at par: holders have a claim against the issuer and may redeem at any time at par value.
• No interest: neither issuers nor crypto-asset service providers may grant interest on EMTs.
• Safeguarding of funds: e-money institutions must safeguard the funds received; a substantial share must be held as deposits with credit institutions — at least 30 percent, rising to at least 60 percent for significant EMTs.
• Significant EMTs: where a token meets at least three of the seven criteria in Article 43 of MiCA — among them more than 10 million holders, more than EUR 5 billion in value, and more than 2.5 million transactions and EUR 500 million per day — stricter requirements apply, and for e-money institutions the EBA takes over supervisory responsibilities.

A further safeguard targets monetary sovereignty: where a stablecoin referencing a non-EU currency (such as the US dollar) is used widely as a means of exchange within a currency area of the Union, MiCA sets thresholds of one million transactions and EUR 200 million per day above which the issuer must stop issuing. It is one reason why the EU's stablecoin market is structurally tilting toward euro tokens.

The Market Two Years On

Because crypto-asset service providers may only offer EMTs from authorised issuers, several large dollar stablecoins without MiCA authorisation were removed from EU trading venues. At the same time, regulated issuers entered the market: German and other European e-money institutions launched euro tokens, and a consortium of European banks set up Qivalis in Amsterdam to issue a euro stablecoin under Dutch supervision. How far stablecoins issued jointly inside and outside the EU — so-called multi-issuance — are compatible with MiCA has been contested between EU institutions; issuers should follow the supervisory position closely before relying on such structures.

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Under MiCA, a euro stablecoin is not a crypto experiment. It is e-money with a white paper — and it brings all of e-money's obligations with it.

The Second Licence: Payments Services for EMT Transfers

Because EMTs are also electronic money, services around them can be payment services. The EBA clarified in June 2025, in an opinion on the interplay between PSD2 and MiCA, that transferring EMTs on behalf of customers — and custody that enables such transfers — should be treated as payment services. It asked supervisors to refrain from enforcement only until 1 March 2026. Since then, crypto-asset service providers offering these services generally need a payment services authorisation (PSD2) in addition to their MiCA licence, or must work with a licensed payment service provider. For exchanges and wallets that built their business on MiCA alone, this has become a real licensing workstream.

What DACH Fintechs Should Plan

1. 01Issuers: plan the EMI or banking route, white paper, reserve management, and redemption processes as one programme — including the path to “significant” status.
2. 02Platforms and wallets: review whether EMT services require a payment licence or a partner, and document the interplay between MiCA and payments law.
3. 03Payment fintechs: assess EMTs as a settlement option for cross-border or 24/7 use cases — with clear classification of each product flow.
4. 04Treasury teams: evaluate which euro tokens meet internal counterparty and liquidity requirements before accepting them.

Conclusion

MiCA has turned stablecoins into a regulated form of money — with issuer licences, reserve rules, and redemption rights. For fintechs, the opportunity is real, but so is the licensing architecture around it. Aegiron Capital Group supports issuers, platforms, and payment fintechs entering the DACH market with stablecoin offerings and runs the preparation as a project; legal structuring and legal advice come from the law firm you engage.