MiCA Stablecoin Rules: EMT vs ART, Significant Tokens, Delistings

At one minute before midnight on 31 March 2025, Binance switched off spot trading pairs for nine stablecoins for users in the European Economic Area, among them USDT, FDUSD, TUSD, DAI and PAXG. The world's largest stablecoin had not been made illegal to hold. It simply had no authorised issuer under the EU's Markets in Crypto-Assets Regulation, and platforms that wanted to keep their own licences could no longer list it. Fifteen months later, with MiCA's last transitional window having shut on 1 July 2026, that sorting is complete.

MiCA is often described as one stablecoin law. It is really two regimes with different rules, different supervisors and very different commercial outcomes. Getting the category right is the first question any issuer, exchange or corporate treasurer in Europe has to answer.

Two boxes: e-money tokens and asset-referenced tokens

MiCA's stablecoin rules, in Titles III and IV, have applied since 30 June 2024. Everything that aims to hold a stable value lands in one of two boxes.

• E-money tokens (EMTs) reference a single official currency. USDC, EURC and the bank-issued euro coins sit here. Only an authorised electronic money institution or a credit institution may issue one, and holders get a claim on the issuer at par.
• Asset-referenced tokens (ARTs) reference anything else: a basket of currencies, a commodity such as gold, other crypto-assets or a mix. A gold-linked token would be an ART.

The EMT box is the one the market has chosen. As of mid-2026, no ART issuer had been authorised anywhere in the EU, according to independent trackers of the ESMA register. The ART regime is heavier, closer to running a small bank's treasury, and without a clear payments use it has drawn no takers.

The reserve and own-funds figures come straight from Article 54 and Article 45 of the regulation. Readers comparing this with the American approach should start with our GENIUS Act and MiCA explainer.

The significance test, criterion by criterion

The European Banking Authority moves into the frame once a token becomes "significant". Article 43 sets seven criteria, and the same test is applied to EMTs. A token is classified when at least three are met:

1. More than 10 million holders.
2. Value issued, market capitalisation or reserve size above EUR 5 billion.
3. Average daily transactions above 2.5 million in number and EUR 500 million in value.
4. The issuer is a designated gatekeeper under the Digital Markets Act.
5. Significant international activity, including use in payments and remittances.
6. Interconnectedness with the financial system.
7. The issuer offers at least one other token or crypto-asset service.

Read that list as a large dollar coin would. A token with EUR 5 billion-plus in circulation already trips criterion two. A global issuer offering both a dollar and a euro token trips criterion seven. International use trips criterion five almost by definition. In other words, any big global EMT is likely to be significant on qualitative grounds alone, well before it reaches 10 million EU holders. The gatekeeper criterion is aimed squarely at the largest technology platforms.

Worked example: what significance costs

Take a hypothetical asset-referenced token with an average reserve of EUR 6 billion over the past six months. Under Article 35, own funds must be the highest of EUR 350,000, 2% of the average reserve, or a quarter of last year's fixed overheads. Assume overheads of EUR 80 million, so a quarter is EUR 20 million.

• Floor: EUR 0.35 million
• 2% of EUR 6 billion: EUR 120 million (the binding figure)
• Quarter of overheads: EUR 20 million

If the token is classified as significant, Article 45 lifts the percentage to 3%, so own funds jump to EUR 180 million, an extra EUR 60 million of capital that earns nothing for holders. The draft liquidity standards must also require a minimum deposit in each referenced currency of no less than 60% of the amount referenced in that currency.

For an EMT the arithmetic is different but just as concrete. An issuer holding EUR 1 billion of funds from token holders must keep at least EUR 300 million in separate accounts at credit institutions under Article 54, with the remainder in high-quality liquid assets. Because EU banks hold those deposits, and because issuers cannot pay interest to holders, the margin left after costs depends heavily on deposit rates. Our piece on how stablecoin issuers make money shows why that 30% floor squeezes European economics relative to a US issuer holding mostly Treasury bills.

These are stylised numbers to show the mechanics. Firms considering issuance should take advice from qualified EU counsel.

The cap that worries dollar coins

The clause that gets less attention but matters most for payments is Article 23. If an ART's estimated quarterly average use as a means of exchange inside a single currency area exceeds 1 million transactions and EUR 200 million a day, the issuer must stop issuing and present a plan within 40 working days to bring usage back below those levels. Article 58 applies the same mechanism to EMTs denominated in a currency that is not an official currency of a member state, which means dollar EMTs.

MiCA welcomes dollar stablecoins as trading tools and quietly caps them as money.

The policy intent is plain: the EU does not want a dollar token becoming everyday money inside the euro area. A dollar coin can be held, traded and used for settlement, but if it starts powering millions of daily retail payments in the eurozone, its issuer hits a wall. For merchants and payment firms planning on-chain acceptance in Europe, that is a strong argument for euro EMTs at the checkout.

How USDT left European order books

The delisting wave followed a clear sequence. On 17 January 2025, ESMA and the European Commission told national authorities to bring crypto-asset service providers into line on non-compliant ARTs and EMTs as soon as possible and no later than the end of the first quarter. Crypto.com set a 31 January 2025 date for delisting USDT and nine other tokens for European users, as The Defiant reported. Binance followed on 31 March, allowing sell-only trading until the cut-off, per BeInCrypto via TradingView.

Two details are often lost. First, holding USDT in a self-custody wallet in the EU remains lawful; the rules bite on offers to the public and on services provided by licensed platforms. Second, the restriction is about the issuer, not the asset design. USDT has no MiCA-authorised issuer, so it does not appear in the EMT register at all. Our USDT vs USDC comparison covers why one of the two big dollar coins chose to come inside the regime and the other did not.

Who is inside the tent

The authorised side is now a recognisable roster: Circle with USDC and EURC, Societe Generale-Forge with EURCV and USDCV, Paxos's EU entity, Banking Circle's EURI, Monerium's EURe, StablR, Quantoz and AllUnity among them. Most tokens are euro-denominated, with dollar, sterling and Swiss franc tokens in the mix.

Scale is the problem. The ECB's April 2026 Macroprudential Bulletin, cited by Forbes, put euro stablecoins at about EUR 450 million in January 2026, up from EUR 50 million two years earlier but still roughly 0.2% of a stablecoin market worth around $300 billion. A ninefold rise sounds impressive until you set it next to the dollar side. MiCA has made the EU the most legally certain place to issue a euro coin; it has not yet made anyone want one at scale. For newer entrants, see beyond USDT and USDC.

Platforms: the end of grandfathering

The issuer rules have been live since 2024. What changed on 1 July 2026 was the platform side. Member states could let existing crypto firms keep operating under national rules for up to 18 months while they sought a MiCA authorisation. Some cut that short: the Netherlands, Finland, Latvia, Hungary and Slovenia closed their windows on 30 June 2025 and Sweden on 30 September 2025. The final outer limit was 1 July 2026, according to Elliptic, which counted 213 authorised CASP entries across 23 jurisdictions on ESMA's interim register just before the deadline. December 2025 was the busiest month, with 41 authorisations. Every one of those licensed platforms is bound to list only compliant stablecoins. For the licence types involved, see CASP, VASP and MTL licences explained.

What to watch next

• Second half of 2026: the Qivalis consortium of European banks, which started with nine banks in September 2025 and added BNP Paribas by December, targets launch of a euro stablecoin. It is the first real test of whether bank-issued euro EMTs can grow.
• EBA significance decisions: the first formal classification of a large EMT as significant would bring EBA into day-to-day supervision and six-monthly independent audits under Article 58.
• Digital euro legislation: the ECB moved the project to its next phase on 30 October 2025. A pilot is possible from mid-2027 and issuance no earlier than 2029, if the regulation passes in 2026. See our digital euro explainer.
• Transatlantic equivalence: the US GENIUS Act requires Treasury to judge whether foreign regimes are comparable. MiCA is the obvious first candidate, which matters for euro EMTs seeking US distribution.

Our view: MiCA did what it set out to do on legal certainty and consumer claims, and its usage caps are a deliberate monetary-sovereignty tool rather than an accident. The open question is commercial. If euro coins stay below one percent of the market, Europe will have built a fine regulatory house that mostly hosts dollar tenants. For a wider view across jurisdictions, see stablecoin regulation by country.

About this researchMuffinPay InsightsIndependent analysis of stablecoins, CBDCs, cross-border payments and digital public infrastructure. Every figure is linked to its source. Read our editorial standards →