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MiCA Stablecoin Licence: How to Issue an EMT or ART in Europe (2026)

Published 5 May 2026 · Last reviewed 17 October 2026 · Buckingham Capital Consulting
Contents
  1. What is a MiCA stablecoin licence?
  2. EMT or ART: the difference
  3. Who can issue an EMT?
  4. Who can issue an ART?
  5. What goes into the white paper
  6. Choosing the issuing member state
  7. Reserve requirements
  8. Redemption rights
  9. Recovery and redemption plans
  10. What it costs to issue a stablecoin
  11. Running an issuer day to day
  12. Significance and EBA supervision
  13. Can I issue a US dollar stablecoin in the EU?
  14. Are algorithmic stablecoins allowed?
  15. Payment services and the PSD2 overlap
  16. The authorisation process for an EMT or ART issuer
  17. How the UK and US compare
  18. Frequently asked questions
Key takeaways
  • Only credit institutions and electronic money institutions may issue e-money tokens (EMTs); an EMI needs initial capital of at least €350,000.
  • ART issuers hold own funds of the highest of €350,000, 2% of average reserve assets and one quarter of fixed overheads, rising to 3% of reserves if significant.
  • EMT holders can redeem at par at any time and free of charge; at least 30% of EMT funds are held as bank deposits, 60% for significant tokens.
  • A token becomes significant when three Article 43 criteria are met, such as more than 10 million holders or more than €5 billion in value; EMTs use the same criteria.
  • Non-EU currency tokens must stop issuing when daily use as a means of exchange exceeds 1 million transactions and €200 million.
  • The EBA transition for CASPs providing EMT payment services without PSD2 authorisation ended on 2 March 2026.

What is a MiCA stablecoin licence?

MiCA, the EU Markets in Crypto-Assets Regulation (Regulation (EU) 2023/1114), does not use the word stablecoin. It creates two categories of token that aim to hold a stable value, each with its own authorisation route. An e-money token (EMT) references one official currency, such as the euro or the US dollar. An asset-referenced token (ART) references anything else: several currencies, a commodity such as gold, other crypto-assets, or a basket.

The rules for issuers, in Titles III and IV of MiCA, have applied since 30 June 2024, six months before the rest of the Regulation. No one may make a public offer of an ART or EMT in the EU, or seek its admission to trading, unless the issuer is authorised for that token. The two categories are exclusive: a token is either an EMT, an ART or neither, and the classification decides who may issue it.

Issuing a token is separate from providing services in it. An exchange or custodian that lists or holds stablecoins issued by others needs CASP authorisation, explained in our MiCA CASP licence guide, but not issuer authorisation.

EMT or ART: the difference

The EMT route suits a token pegged one-for-one to a single currency, and uses the established EU e-money framework. The ART route covers every other reference value and is a MiCA-specific authorisation. The table compares the two.

FeatureE-money token (EMT)Asset-referenced token (ART)
Reference valueOne official currencySeveral currencies, commodities, crypto-assets or a basket
Legal natureElectronic moneyMiCA-specific crypto-asset
Who may issueCredit institutions and electronic money institutionsCredit institutions and authorised ART issuers
ReserveFunds received, invested in the same currency in secure, low-risk assetsA diversified reserve matching the reference assets, held by a separate custodian
RedemptionAt par, at any time, free of chargeAt any time, at the market value of the referenced assets or by delivering them
InterestProhibitedProhibited
White paperNotified to the regulator before publicationApproved by the regulator with the authorisation
SignificanceSame criteria as ARTs (Article 56)10 million holders, €5 billion value, 2.5 million transactions and €500 million a day, among other criteria (Article 43)

Who can issue an EMT?

Under Article 48, only a credit institution or an electronic money institution (EMI) may make a public offer of an EMT or seek its admission to trading. For non-bank issuers, the EMI authorisation is therefore the EMT authorisation, granted under the Electronic Money Directive (Directive 2009/110/EC) as implemented in the home member state, with the MiCA rules on white papers, reserves and redemption on top.

What an EMI needs

  • Initial capital of at least €350,000.
  • Ongoing own funds of at least 2% of average outstanding e-money (Method D), with higher requirements for significant tokens under Article 58.
  • Directors and key staff who are fit and proper, with effective management in the home member state.
  • Safeguarding of funds received from token holders.
  • An AML and sanctions framework covering token issuance, redemption and secondary market monitoring.
  • Operational resilience under DORA, the EU digital operational resilience law.

EMIs that issue stablecoins are authorised in several member states, including France, Lithuania, Ireland and Malta. The choice of home state for the EMI is covered below.

Banks

A credit institution may issue EMTs without a separate EMI authorisation. It notifies its regulator and prepares the MiCA white paper, and the reserve, redemption and disclosure rules apply in the same way.

The white paper

The EMT white paper describes the issuer, the token, the rights attached, the underlying technology and the risks. It is notified to the home regulator at least 20 working days before publication, but it is not approved, and the issuer is responsible for its content. Marketing must be consistent with it.

Who can issue an ART?

An ART may be offered or admitted to trading only by a credit institution or by an issuer authorised under Article 16 of MiCA. ART issuers do not need EMI status. The authorisation includes regulator approval of the white paper.

ART issuer requirements

  • Registered office in the EU.
  • Own funds of at least the highest of €350,000, 2% of the average amount of reserve assets, and one quarter of the previous year's fixed overheads.
  • Fit and proper directors and suitable shareholders with 10% or more.
  • A governance framework with clear responsibilities, conflicts management and complaints handling.
  • A reserve of assets held separately and in custody with a credit institution, a CASP authorised for custody, or an investment firm.
  • A liquidity management policy and stress testing of redemption.
  • A recovery plan and a redemption plan.
  • A legal opinion that the token is not a financial instrument, an e-money token or otherwise excluded from MiCA.
  • A white paper approved by the regulator.

Authorisation is not required for an ART whose average outstanding value over 12 months does not exceed €5,000,000, or that is offered only to qualified investors and can only be held by them. The issuer still produces a white paper and notifies it to the regulator.

A credit institution issuing an ART does not need separate ART authorisation, but it notifies its regulator, has its white paper approved and meets the reserve and operational rules.

What goes into the white paper

The white paper is the disclosure document for the token. It is the basis on which holders, CASPs and the regulator judge the token, and the issuer is liable for information in it that is incomplete, unclear or misleading.

  • Information about the issuer: identity, management, and, for ARTs, the reserve custodians and other third parties.
  • Information about the token: the reference value, the rights attached and how the stable value is maintained.
  • The offer or admission to trading: the amount, the price, the distribution channels and the CASPs involved.
  • The rights and obligations of holders, including the redemption procedure and its conditions.
  • The underlying technology: the blockchains used and how tokens are created and destroyed.
  • The risks: issuer, token, reserve, technology and redemption risks, stated plainly.
  • The reserve, for ARTs: composition, investment policy, custody and audit.
  • The principal adverse environmental and climate impacts of the consensus mechanism used.

The white paper carries a clear statement that it has not been approved by a regulator (for EMTs) and a summary written for retail readers. It is updated and re-notified whenever a significant new factor or material change affects the information in it.

Choosing the issuing member state

The issuer's home regulator authorises the EMI or ART issuer and supervises it unless the token becomes significant. The choice turns on where management and staff will sit, banking for the reserve, the depth of local e-money expertise and the language of supervision.

Member stateE-money regulatorPoints to weigh
FranceACPRSeveral EMT issuers authorised; supervision in French
LithuaniaBank of LithuaniaLarge EMI population and an English-language process
IrelandCentral Bank of IrelandEnglish-speaking common law base with deep payments expertise
MaltaMalta Financial Services AuthorityEnglish-language process and long experience of crypto regulation
NetherlandsDe Nederlandsche BankStrong payments ecosystem; supervision in Dutch and English
LuxembourgCSSFInstitutional groups and fund infrastructure

The comparison of EU countries for a MiCA licence covers the same regulators from the CASP side, which matters where a group will both issue and distribute its token.

Reserve requirements

EMT reserves

Funds received in exchange for EMTs are invested in secure, low-risk assets denominated in the same currency as the token. Under Article 54, at least 30% of the funds received are always held as deposits in separate accounts at credit institutions. For significant EMTs the deposit share rises to 60%, under the EBA's technical standards on liquidity.

ART reserves

The reserve covers the risks of the referenced assets and the liquidity needed for redemption. It is held separately from the issuer's own assets, with an independent custodian, and invested only in highly liquid financial instruments with minimal market, credit and concentration risk. The issuer publishes the amount of tokens in circulation and the value and composition of the reserve at least monthly, and commissions an independent audit of the reserve every six months.

Rules common to both

  • Reserve assets are not pledged, lent or reused by the issuer.
  • Token holders have a claim on the reserve that ranks ahead of the issuer's general creditors.
  • An EMI issuing EMTs applies its e-money safeguarding rules alongside the MiCA reserve rules; both sets are met in full.

Safeheld, the firm's own safeguarding platform, runs the daily reconciliations that EMIs use to evidence safeguarding of token holder funds; the Safeheld page sets out how it works.

Redemption rights

EMT holders have a right to redeem at any time and at par value, in funds other than e-money, under Article 49. The issuer may not charge a fee for redemption or set conditions that limit the right in practice, and it states the redemption conditions prominently in the white paper.

ART holders have a permanent right of redemption at any time, under Article 39. The issuer pays the market value of the referenced assets or delivers the assets themselves, and publishes its redemption policy. The redemption plan sets out how holders are treated if the issuer cannot meet its obligations, including the orderly sale of reserve assets.

No interest

Neither the issuer nor a CASP may pay interest, or any other remuneration or benefit linked to the length of time a holder keeps an EMT or ART (Articles 40 and 50). A yield-bearing product built on a stablecoin needs separate analysis, because the yield may itself be a regulated investment service or may take the token outside the EMT and ART categories.

Recovery and redemption plans

Every ART issuer, and every EMT issuer through Article 55, maintains two plans. The recovery plan, under Article 46, sets out the measures the issuer will take to restore compliance with the reserve requirements if they are breached, including liquidity fees on redemption, limits on the amount redeemed in a day and suspension of redemption in defined circumstances. The redemption plan, under Article 47, shows how all holders would be repaid in an orderly way if the issuer cannot meet its obligations, including by selling reserve assets.

Both plans are notified to the regulator, reviewed and updated regularly, and tested against scenarios such as a large run on redemptions, the insolvency of a reserve bank or custodian, and a market dislocation in the reserve assets. They are where the regulator tests whether the reserve design works under stress.

What it costs to issue a stablecoin

Regulator fees are set nationally and are a small part of the total. The larger costs are capital, people and the reserve infrastructure.

  • Capital: at least €350,000 for an EMI or ART issuer, held in addition to the reserve. Reserve assets do not count towards own funds.
  • People in the EU: directors, a compliance officer, an MLRO (money laundering reporting officer), and treasury staff to run the reserve.
  • Banking and custody: reserve accounts at several credit institutions to spread exposure, and custodians for any securities held.
  • Assurance: independent reserve audits, the statutory audit and, for ARTs, the six-monthly reserve audit.
  • Technology: smart contracts with mint, burn and freeze controls, security audits of the contracts, and wallet infrastructure.
  • Distribution: agreements with CASPs to list and distribute the token, and market makers to support secondary liquidity.

Reserve income is the main revenue line for most issuers, since interest cannot be passed to holders. The business plan in the application shows how reserve income, issuance and redemption fees where charged, and distribution costs combine over three years.

Running an issuer day to day

Once authorised, an issuer runs a daily operating cycle around the reserve and the token supply.

  • Reconcile tokens in circulation against reserve assets every day, with breaks escalated at once.
  • Control minting and burning, so that tokens are created only against funds received and destroyed on redemption.
  • Apply AML and sanctions checks to every holder who buys from or redeems with the issuer directly, and keep the technical ability to freeze tokens where the law requires.
  • For ARTs, publish tokens in circulation and the reserve's value and composition at least monthly.
  • For non-EU currency tokens with an issue value above €100 million, report quarterly on holders, value and transactions.
  • Monitor the peg and secondary market prices, with a playbook for a loss of peg.
  • Update the white paper and notify the regulator when material facts change.

A group that also provides CASP services in its own token runs these duties alongside its CASP compliance programme.

Significance and EBA supervision

The European Banking Authority (EBA) classifies an ART or EMT as significant when at least three criteria in Article 43 are met. Article 56 applies the same criteria to EMTs.

CriterionThreshold
Number of holdersMore than 10 million
Value of the token or size of the reserveMore than €5 billion
Daily transactionsMore than 2.5 million transactions and €500 million a day on average
Issuer statusThe issuer is a large online platform designated under the Digital Markets Act
International useSignificant use for payments and remittances across borders
InterconnectionLinks with the wider financial system
Wider activityThe issuer issues another ART or EMT and provides at least one crypto-asset service

A significant ART issuer moves to direct EBA supervision, with own funds of 3% of average reserve assets, a remuneration policy, liquidity stress testing and a 60% minimum deposit share in the reserve. For significant EMTs issued by an EMI, the EBA supervises the MiCA requirements while the national regulator keeps supervision under e-money law.

Can I issue a US dollar stablecoin in the EU?

Yes. A token pegged to the US dollar references one official currency, so it is an EMT and must be issued by an EU EMI or credit institution, with US dollar reserves, redemption at par in dollars and a white paper notified to the regulator.

The cap on non-EU currency tokens

For ARTs and for EMTs denominated in a currency that is not an official currency of a member state, Articles 22, 23 and 58 add two rules. Where the issue value exceeds €100 million, the issuer reports quarterly on holders, value and transactions. Where the estimated average number and value of transactions a day linked to use as a means of exchange within a single currency area exceed 1 million and €200 million, the issuer stops issuing the token and submits a plan to bring use below those levels within 40 working days.

A non-EU issuer reaches EU users by establishing an EU EMI, obtaining authorisation and issuing the token through that entity. Reverse solicitation, where the client approaches the firm entirely on its own initiative, is a narrow exception and does not support ongoing issuance to EU users.

Are algorithmic stablecoins allowed?

MiCA does not name algorithmic stablecoins, but its requirements leave no route for them as EMTs or ARTs. Both categories require a reserve of real assets and a redemption right against it, and a supply mechanism driven by an algorithm does not count as a reserve. A token that has no reserve cannot be marketed as stable or as referencing a value.

Hybrid designs, with a partial reserve supported by an algorithm, meet the same rule: the reserve must cover redemption on its own. Projects in this category have restructured with full reserves, rebranded as ordinary crypto-assets under Title II with their own white paper, or left the EU market.

Payment services and the PSD2 overlap

Because EMTs are electronic money, some services involving them are also payment services under PSD2, the EU Payment Services Directive (Directive (EU) 2015/2366). Transferring EMTs for clients, or holding them in custodial wallets used to make payments, can require a payment institution or EMI authorisation alongside MiCA CASP authorisation.

The EBA's No Action Letter of June 2025 gave CASPs a transition to 2 March 2026 to obtain the payments authorisation for these services. Its Opinion of 12 February 2026 asks national regulators to require firms that do not meet its conditions to stop those services until authorised. An EMI already holds the payments permissions, so for many groups the most direct structure is an EMI that issues the EMT and also notifies its regulator to provide custody and transfer of its own tokens under Article 60.

The EU payments reforms that would align these regimes are covered in our article on PSD3 and the EU Payment Services Regulation.

The authorisation process for an EMT or ART issuer

  1. Classify the token. Confirm whether it is an EMT, an ART or a Title II crypto-asset, and obtain the legal analysis the regulator will expect.
  2. Choose the issuing entity and home state. An EMI for an EMT, an ART issuer or bank for an ART, located where management and banking will sit.
  3. Design the reserve. Asset mix, deposit share, custodians, reconciliation and audit, and the liquidity stress tests.
  4. Design redemption. Who can redeem, through which channels, how fast, and the redemption plan for a stressed scenario.
  5. Prepare the file. Programme of operations, three-year financial model, capital calculation, governance, AML, DORA, recovery and redemption plans, and the white paper.
  6. Submit and answer questions. For an ART, the regulator assesses the application and the white paper together; for an EMT issued by an EMI, the e-money authorisation runs first and the white paper is notified before publication.
  7. Launch. Publish the white paper, open the reserve accounts, start reporting, and onboard CASPs to list and distribute the token.

The regulator's statutory periods apply on top of preparation. For EMIs, national e-money law sets a decision within three months of a complete application; firms should plan around 6 to 8 months from submission to authorisation. For ARTs, Articles 20 and 21 give the regulator 60 working days from a complete application to assess it, the EBA and ESMA (and the European Central Bank where relevant) 20 working days to give their opinions, and the regulator 25 working days after that to decide.

How the UK and US compare

The UK regulates stablecoins under its own regime, the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (SI 2026/102). Issuing a qualifying stablecoin in the UK becomes an FCA-authorised activity; the FCA application window opened on 30 September 2026 and runs to 28 February 2027, and the regime commences on 25 October 2027. Stablecoins used widely for payments can be recognised as systemic, bringing Bank of England supervision. The UK has no EMT and ART split, and UK and EU authorisations do not passport into each other. Our article on UK stablecoin payments regulation covers the UK position.

In the US, the GENIUS Act was signed into law on 18 July 2025 and takes effect on the earlier of 18 January 2027 or 120 days after final regulations; the implementing rules are still proposals. Groups issuing in the EU, UK and US run three applications with a shared reserve and governance design but separate entities, regulators and capital. The global stablecoin licence guide compares all three.

Frequently asked questions

What is the difference between an EMT and an ART under MiCA?

An EMT references one official currency and is electronic money. An ART references several currencies, commodities, crypto-assets or a basket; a token cannot be both.

Who can issue an EMT in the EU?

Only credit institutions and electronic money institutions, under Article 48 of MiCA. A non-bank issuer obtains EMI authorisation, with initial capital of at least €350,000.

Who can issue an ART in the EU?

A credit institution or an issuer authorised under Article 16 of MiCA. Own funds are the highest of €350,000, 2% of average reserve assets and one quarter of fixed overheads.

What are the reserve requirements for EMTs?

Funds received are invested in secure, low-risk assets in the same currency, with at least 30% held as deposits at credit institutions, rising to 60% for significant EMTs.

When is a stablecoin significant under MiCA?

When at least three criteria in Article 43 are met, such as more than 10 million holders, more than €5 billion in value, or more than 2.5 million transactions and €500 million a day. The same criteria apply to EMTs.

Can a stablecoin issuer pay interest to holders?

No. Neither the issuer nor a CASP may pay interest or any benefit linked to how long a holder keeps the token.

Can I issue a US dollar stablecoin in the EU?

Yes, as an EMT through an EU EMI or bank. Where daily use as a means of exchange exceeds 1 million transactions and €200 million, the issuer must stop issuing and present a plan to reduce use.

Are algorithmic stablecoins allowed under MiCA?

Not as EMTs or ARTs, because both require a reserve of real assets and a redemption right against it. An algorithm does not count as a reserve.

References

  1. Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA), EUR-Lex
  2. Directive 2009/110/EC on electronic money institutions, EUR-Lex
  3. Directive (EU) 2015/2366 on payment services (PSD2), EUR-Lex
  4. EBA: actions at the end of the transition under its No Action Letter on PSD2 and MiCA, 12 February 2026
  5. ESMA: Markets in Crypto-Assets Regulation and the interim register of EMT and ART white papers
  6. FCA: new regime for cryptoasset regulation

About Buckingham Capital Consulting

Buckingham Capital Consulting has obtained EMI authorisations in the UK and the EU since 2013, including the Central Bank of Ireland EMI licence for Own Solutions and FCA EMI authorisations for Dzing Finance, Hryze and HFS. For stablecoin issuers, the firm prepares the EMI or ART application, the reserve and redemption design and the white paper, and coordinates parallel UK and US filings.

Speak to an expert: WhatsApp +44 7563 115980, Telegram @buckinghamcapital or info@buckinghamcapitalconsulting.co.uk.

This article is general information, reviewed against the regulator’s published requirements on the date shown. It is not legal advice; the regulator’s current publications take precedence.