Multi-currency
Stablecoin referencing a basket of currencies
"If the token references several official currencies, it is not an EMT: it falls under the ART regime and requires authorization from the Bank of Spain."
Asset-Referenced Tokens (ART) under MiCA
Asset-referenced tokens (ART) are crypto-assets that stabilize their value against a basket of assets. Under MiCA, issuing them in Spain requires authorization from the Bank of Spain and an approved white paper (MiCA Art. 16(1)). We help you structure the project: reserve of assets, capital, redemption and governance.
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Tell us about your stablecoin project and we will tell you whether it is an ART, an EMT or something else.
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- ART issuance reserved under
- Art. 16(1)
- ART and EMT rules applicable since
- June 30, 2024
- Authorizing authority
- Bank of Spain
- Reference legislation
- Reg. (EU) 2023/1114
How we help
Issuing an ART, step by step
Six workstreams to take an asset-referenced token project from idea to Bank of Spain authorization, in line with MiCA.
Classification
ART, EMT or another crypto-asset?
We analyze the token’s design to determine whether it is an ART (basket of assets), an EMT (a single fiat currency) or another Title II crypto-asset, because the entire regime depends on it.
Learn more →
ARTEMTTitle IIClassification
Authorization
Authorization and white paper
We prepare the authorization application to the Bank of Spain and the white paper required by MiCA Art. 16(1) to be able to offer the ART.
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Bank of SpainWhite paperArt. 16
Reserves
Reserve of assets
We design the reserve that backs the ART: composition, custody, segregation and investment, in line with MiCA requirements.
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ReserveCustody
Capital
Capital and redemption
We calculate the own funds required and set up the holders’ right of redemption at the market value of the referenced assets.
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Own fundsRedemption
AML
Governance and anti-money laundering
We structure the corporate governance, conflict-of-interest management and anti-money laundering program that accompany the issuance.
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GovernanceSEPBLAC
Distribution
Distribution and CASP services
We coordinate the ART issuance with the providers that distribute the token or hold it in custody, which need their own CASP authorization from the CNMV.
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CASPDistribution
Use cases
Who issues an ART
Multi-currency stablecoins, commodity-backed tokens or baskets of assets: different projects that fall under MiCA’s ART regime.
Commodity
Commodity-backed token
"Tokens referencing gold or other commodities are structured as ARTs, with their own reserve of assets and redemption."
Mixed basket
Value referencing several assets
"When the reference combines currencies, crypto-assets and other assets, the reserve design is the heart of the project."
Credit institution
A bank issuing an ART
"A credit institution can issue ARTs once the Bank of Spain has approved its white paper."
What is at stake
Issuing an ART without complying with MiCA has consequences
The ART regime is demanding: prior authorization, reserves, capital and redemption. Offering an asset-referenced token without authorization is a serious infringement that the Bank of Spain can pursue.
MiCA · Art. 16
Authorization
In Spain, only legal persons authorized by the Bank of Spain, or credit institutions with an approved white paper, can issue ARTs.
Bank of Spain
Supervisor
The issuance of ARTs and EMTs (Titles III and IV of MiCA) falls under the Bank of Spain, not the CNMV.
Inadequate reserves: a poorly designed or unsegregated reserve puts redemption, and the authorization itself, at risk.
Unauthorized offer: offering an ART or admitting it to trading without authorization breaches MiCA and can lead to penalties.
June 30, 2024
In force
The ART and EMT rules have applied since June 30, 2024. This is not a future regime.
Confusing ARTs with EMTs: misclassifying the token leads to applying the wrong regime and redoing the entire project.
Want to issue an asset-referenced token?
We help you classify the token, design the reserve, calculate the capital and prepare the authorization application and the white paper for the Bank of Spain.
Frequently asked questions
Asset-referenced tokens: common questions
What is an asset-referenced token (ART)?
It is a crypto-asset that stabilizes its value by referencing one or more assets: a basket of official currencies, commodities, other crypto-assets or a combination. It is one of the two categories of “stablecoin” regulated by MiCA, together with the EMT.
How does an ART differ from an EMT?
An EMT references its value to a single official currency (for example, the euro or the dollar). An ART references its value to a basket of assets or to several currencies. That difference determines the regime, who is permitted to issue the token and the applicable requirements.
Who can issue an ART in Spain?
Under Article 16(1) of MiCA, only legal persons with the required authorization from the Bank of Spain, or credit institutions whose white paper has been approved in advance by the Bank of Spain.
Who supervises ARTs: the Bank of Spain or the CNMV?
The Bank of Spain. The issuance of ARTs and EMTs is covered by Titles III and IV of MiCA, which fall within its remit. The CNMV handles other crypto-assets (Title II) and the authorization of CASPs (Title V).
What is the white paper?
It is the disclosure document that describes the token, the issuer, the holders’ rights, the reserve of assets and the risks. For an ART, it must be approved by the Bank of Spain before the token is offered or admitted to trading.
What are the requirements for the reserve of assets?
The reserve must back the value of the ART, be segregated from the issuer’s own assets, be held in appropriate custody and allow holders to obtain redemption at the market value of the referenced assets, subject to rules on its composition and investment.
Since when have these rules applied?
The ART and EMT rules have applied since June 30, 2024. Since that date, offering an ART or admitting it to trading has been reserved to the issuer or to persons with the issuer’s written consent.
Do I also need a CASP license?
Issuing the ART is one thing; providing services involving it (custody, exchange, distribution) is another. Those services require CASP authorization from the CNMV. Many projects combine the issuance authorization with agreements with CASPs.
Could my token actually be a financial instrument?
Yes, it is possible. If the token grants rights typical of a share or a bond, it could fall outside MiCA and be governed by MiFID II and securities markets legislation. Classifying it correctly from the start avoids serious mistakes.
Practical guide
How to structure an ART issuance
Issuing an asset-referenced token is not just launching a token. It means classifying it correctly, designing a robust reserve, calculating the capital, setting up redemption and obtaining authorization from the Bank of Spain. The order matters.
First, what your token is
First of all, you need to determine whether the token is an ART, an EMT, another Title II crypto-asset or even a financial instrument under MiFID II. The entire regime and the competent supervisor depend on that classification.
The heart of the project
The reserve of assets backs the value of the ART. Its composition, custody, segregation and investment are the core of the authorization: a weak reserve makes the project unviable.
Bank of Spain and white paper
The issuance requires authorization from the Bank of Spain and an approved white paper (MiCA Art. 16(1)). Without that step, offering the token or admitting it to trading is an infringement.
From idea to authorized ART in 10 steps
- Define the token’s economic design and the assets it references.
- Classify the token: ART, EMT, other crypto-asset or financial instrument.
- Confirm that the issuer is an eligible legal person or a credit institution.
- Design the reserve of assets: composition, custody, segregation and investment.
- Calculate the own funds required under MiCA.
- Set up the right of redemption at the market value of the referenced assets.
- Structure corporate governance, conflicts of interest and the AML program.
- Draft the white paper with all the information MiCA requires.
- File the authorization application and the white paper with the Bank of Spain.
- Coordinate distribution and custody with CASPs authorized by the CNMV.
Does your project combine issuance and services? See the MiCA and crypto-assets framework or CASP authorization.
ARTs in practice
From stablecoin to authorization: how an ART takes shape
An asset-referenced token project lives or dies by its reserve and its correct classification. This panel sets out how to build an ART that the Bank of Spain can authorize.
1) ClassifyClassify the token
We determine whether it is an ART, an EMT, another Title II crypto-asset or a financial instrument, because each classification opens a different regime.
- ART vs. EMT
- Title II / MiFID II
- Competent supervisor
2) ReserveDesign the reserve
We define the reserve’s composition, custody, segregation and investment, which is what backs the value and the redemption of the ART.
- Composition
- Custody and segregation
- Investment policy
3) Capital and redemptionCapital, redemption and governance
We calculate own funds, set up the holders’ right of redemption and structure corporate governance and AML.
- Own funds
- Redemption at market value
- Governance and AML
4) AuthorizeWhite paper and authorization
We draft the white paper and prepare the authorization application to the Bank of Spain under MiCA Art. 16(1), handling its requests for information.
Tip: the initial classification determines everything. If a project designed as an EMT is actually an ART (or vice versa), the reserve, capital and authorization all have to be redone. Start there.
Quick decisionWhich regime applies to your token?
One currency
References a single official currency: it is an EMT (Bank of Spain).
Basket of assets
References several assets or currencies: it is an ART (Bank of Spain).
Financial rights
If it works like a share or a bond: MiFID II, not MiCA.
ART playbook
ARTs vs. EMTs, point by point
Reference
Basket of assets: several currencies, commodities or other crypto-assets.
A single official currency (for example, the euro or the dollar).
Issuer
Legal person authorized by the Bank of Spain, or a credit institution.
Credit institution or electronic money institution.
Document
White paper approved by the Bank of Spain (Art. 16(1)).
White paper notified in advance to the Bank of Spain (Art. 48(1)).
Supervisor
Bank of Spain.
Bank of Spain.
Redemption
At the market value of the referenced assets.
At par with the referenced currency.
Mistakes that block an ART issuance
Avoiding them is what separates a project that can be authorized from one that is not viable.
- Classifying as an EMT what is actually an ART (or vice versa).
- Designing a reserve without adequate segregation or custody.
- Failing to set up a clear right of redemption for holders.
- Offering the token before authorization and approval of the white paper.
- Forgetting that distribution and custody require CASPs.
Practical glossary
Key ART concepts
If your project falls under the asset-referenced token regime, these terms appear in the white paper and in the application to the Bank of Spain. Understanding them avoids classification mistakes.
ARTMiCA
Asset-referenced token
A crypto-asset that stabilizes its value by referencing a basket of assets (currencies, commodities or other crypto-assets).
Title III of MiCA.
EMTMiCA
E-money token
A crypto-asset that stabilizes its value by referencing a single official currency. Only credit institutions and electronic money institutions can issue it.
Title IV of MiCA.
Art. 16(1)Authorization
Who can issue
The MiCA provision that reserves ART issuance to legal persons authorized by the Bank of Spain or credit institutions with an approved white paper.
The basis for the issuer’s authorization.
White paperDisclosure
Disclosure document
Describes the token, the issuer, the rights, the reserve and the risks. For an ART, it must be approved by the Bank of Spain.
A prerequisite for the offer.
Reserve of assetsBacking
Assets backing the token
A segregated pool of assets that backs the value of the ART and allows holders to obtain redemption.
Custody + segregation + investment.
RedemptionRight
The holder’s right
The right to recover the value of the token. For an ART, at the market value of the referenced assets.
A key safeguard for investors.
Bank of SpainSupervisor
ART/EMT authority
The competent authority in Spain for the issuance of ARTs and EMTs (Titles III and IV of MiCA).
Separate from the CNMV (Titles II and V).
CASPServices
Service provider
Anyone who provides services involving the ART (custody, exchange, distribution) needs CASP authorization from the CNMV.
Complements the issuance authorization.
MiFID IIBoundary
Financial instrument
If the token grants rights typical of a share or a bond, it falls outside MiCA and is governed by MiFID II and securities legislation.
A boundary to watch when classifying the token.
Contact
Book a call
Tell us about your token’s design and the assets it references, and we will tell you whether it is an ART and what you need to issue it.
Asset-referenced tokens (ART) under MiCA: the regime in Spain
Asset-referenced tokens (ARTs) are one of the two categories of “stablecoin” regulated by Regulation (EU) 2023/1114, known as MiCA. They are crypto-assets that aim to stabilize their value by referencing a basket of assets: several official currencies, commodities, other crypto-assets or a combination. Their regime is demanding and, in Spain, their issuance and supervision fall to the Bank of Spain.
What exactly an ART is
Unlike the e-money token (EMT), which references a single official currency, an ART references a set of assets. That is why its reserve is more complex and its regime is different. Classifying the token correctly (ART, EMT, other crypto-asset or financial instrument) is the first step and shapes everything else.
Who can issue an ART
Under Article 16(1) of MiCA, as a general rule, ARTs can only be issued in Spain by legal persons authorized by the Bank of Spain or by credit institutions whose white paper has been approved in advance by the Bank of Spain. Since June 30, 2024, offering an ART or seeking its admission to trading has been reserved to the issuer or to persons with the issuer’s written consent.
Reserves, capital and redemption
The issuer must set up a reserve of assets that backs the value of the token, is segregated and is held in proper custody. It must also meet own funds requirements and guarantee the holders’ right of redemption at the market value of the referenced assets. On top of this come obligations on governance, conflict-of-interest management and anti-money laundering.
Who supervises and how CASPs fit in
In Spain, the issuance of ARTs and EMTs (Titles III and IV of MiCA) is the responsibility of the Bank of Spain, while the CNMV handles other crypto-assets and the authorization of CASPs (crypto-asset service providers). That is why an ART project usually combines the issuance authorization from the Bank of Spain with agreements with CASPs that distribute the token or hold it in custody.
MiCA and licenses
Related areas
Official sources
Key legislation, linked to the official text:
- Regulation (EU) 2023/1114 of May 31, 2023 on markets in crypto-assets (MiCA)EUR-Lex · Official Journal of the EU
Legislation and links reviewed in .