The stablecoin provisions of MiCA started applying on 30 June 2024, six months before the rest of the regulation. That gap was deliberate. Brussels wanted the payment-like tokens in scope first, because those are the ones ordinary people hold as if they were money, and because a token that breaks its peg looks a lot like a bank run without a bank. Everything that has happened since to European exchange listings follows from that six month head start.
Two categories, and almost everything is the first one
MiCA splits pegged tokens by what they reference. An e-money token, EMT in the regulation's shorthand, references a single official currency. An asset-referenced token, ART, references anything else: a basket of currencies, a commodity, a pool of assets, or some combination that is not one sovereign currency.
In practice the market is overwhelmingly EMTs. A token tracking the euro or the dollar one for one is an e-money token, and it lands in a category that European law already understood well, because electronic money has been regulated in the EU since long before crypto existed. That is why the EMT rules read like the e-money regime with a distributed ledger attached. Firms already familiar with the electronic money institution regime will recognise most of the machinery.
An ART is the harder file. There is no existing prudential template for a token backed by a basket, so MiCA had to write one: authorisation from a competent authority, a reserve of assets managed and held separately from the issuer's own funds, custody arrangements, valuation, a redemption policy and its own capital requirement. Tokens that reach the size thresholds set in the regulation are designated significant and pass under direct supervision at European level, with higher requirements attached.
What an EMT issuer has to be
The gate is narrow and it comes first. An EMT may only be issued by an authorised credit institution or an authorised electronic money institution. There is no path where a software company mints a euro token and applies for something afterwards. Before offering the token to the public or seeking admission to trading, the issuer notifies a crypto-asset whitepaper to its competent authority, and that document has a prescribed content and carries liability for what it says.
Two obligations do most of the consumer protection work. The first is redemption at par, at any time, from the issuer, in the referenced currency. The second is the prohibition on interest: neither the issuer nor a service provider distributing the token may grant a return linked to how long a holder keeps it. Together these say a stablecoin is a payment instrument and not a savings product, which closes the door on the yield products that defined the previous cycle.
Behind those sit the safeguarding rules. Funds received in exchange for tokens must be segregated and protected, with a set minimum share held as deposits at credit institutions, and a higher share once a token is designated significant. There is also a restriction aimed at monetary sovereignty: EMTs denominated in a currency other than the euro face limits when they are used widely as a means of exchange inside the EU, measured against daily thresholds written into the regulation.
| E-money token (EMT) | Asset-referenced token (ART) | |
|---|---|---|
| References | One official currency | A basket, a commodity, or a mix of assets |
| Who may issue | Credit institution or authorised EMI only | Credit institution, or an entity authorised under MiCA for ARTs |
| Pre-launch document | Whitepaper notified to the competent authority | Whitepaper approved as part of authorisation |
| Redemption | At par, at any time, in the referenced currency | Per the redemption policy, in funds or by delivering the referenced assets |
| Interest to holders | Prohibited | Prohibited |
| Backing | Safeguarded funds, part held as bank deposits | A reserve of assets held separately, with custody and valuation rules |
The part that changed daily life for firms
Most trading firms are not issuing anything. They are on the other side of the rule: they accept a token from a client, hold it briefly, convert it and credit an account. What MiCA changed for them is that a token whose issuer does not meet the conditions may not be offered to the public or admitted to trading in the EU, and crypto-asset service providers inside the perimeter had to stop making non compliant tokens available. Several European venues restricted or removed specific tokens for exactly that reason during 2024 and 2025.
So the operational question is no longer which chain a token settles on, it is who issued it and under what authorisation. That is a different diligence exercise from the one most payment teams were running, where the debate was about network fees and confirmation times, the sort of thing covered in the comparison of TRC20 and ERC20 transfers. Both questions still matter. Only one of them can shut the channel overnight.
A firm outside the EU serving EU residents does not get a free pass by being incorporated elsewhere. The relevant test is where the offering is directed, and marketing a euro deposit channel to clients in Germany is an offering directed at Germany. Reverse solicitation is narrower than most offshore operators assume, and it is being read narrowly by supervisors.
What to do about it if you take crypto deposits
Treat the token list as a controlled document with an owner and a review date, in the same way the payment method list is controlled. Record for each accepted token who the issuer is, what authorisation it holds, which entity of yours is accepting it and for which client jurisdictions. When a processor emails to say a token is being delisted on a European venue, that record is what turns a panic into a scheduled change.
Keep the treasury side honest as well. A firm that credits a client in euro on receipt of a dollar pegged token is carrying currency risk between receipt and conversion, on top of any peg risk, and that exposure belongs in a policy rather than in the head of whoever runs the wallet. The practical mechanics of accepting tokens for account funding are set out in the guide to stablecoin deposits, and the wider licensing picture sits in the article on the MiCA licence and in the comparison with the older national VASP registrations it replaced.
The direction of travel is not subtle. Payment tokens are being pulled toward the rules that already govern payments, with named issuers, redeemable claims and supervised reserves. Firms that built deposit flows around whichever token was cheapest to move will keep rebuilding them. Firms that built around who stands behind the token will not.
"Clients do not care which title of the regulation a token sits under. They care that the withdrawal arrives. Our job is to be sure the token we accept on Monday is still legal to accept on Friday."
— Roman Onta, Executive Director, SINGUARD
Key Takeaways
- MiCA has no stablecoin category: a token pegged to one official currency is an e-money token, anything else pegged is an asset-referenced token.
- Only credit institutions and authorised electronic money institutions may issue EMTs, and holders keep a right of redemption at par at any time.
- Paying interest on either token type is prohibited, which removes yield products from the regulated EU market.
- For firms taking deposits, the question that can close a channel is who issued the token and under what authorisation, so keep the accepted token list under formal review.
Frequently Asked Questions
What is the difference between an EMT and an ART under MiCA?
An e-money token references a single official currency and may only be issued by an authorised credit institution or electronic money institution. An asset-referenced token references anything else, such as a basket of currencies, a commodity or a mix of assets, and its issuer needs a separate MiCA authorisation with a reserve of assets and its own funds requirement. Most stablecoins in daily use reference one currency, so they fall in the e-money token category.
Can an EU firm still accept USDT deposits?
It depends on whether the token is being offered to the public or admitted to trading in the EU by an issuer that meets the MiCA conditions. Crypto-asset service providers in the EU had to stop offering tokens that do not comply, and several European venues delisted or restricted specific tokens for that reason. A firm taking crypto deposits should confirm the current status of each token with its own counsel and its payment provider rather than assuming last year's answer still holds.
Do stablecoin holders earn interest under MiCA?
No. MiCA prohibits issuers and crypto-asset service providers from granting interest on e-money tokens and asset-referenced tokens, including any benefit linked to the length of time a holder keeps the token. The point of the rule is to keep these instruments working as payment tools rather than as deposit substitutes that compete with regulated banking products.