Payments and remittances
A stable digital means of payment
"EMTs work as a tokenized representation of the euro or the dollar: instant, programmable and interoperable 24/7 payments, with 1:1 backing and a right of redemption."
E-Money Tokens (EMT) under MiCA
Expert legal advice on MiCA EMTs (e-money tokens): credit institution or electronic money institution license, white paper notified to the Bank of Spain, reserves, right of redemption at par value and ongoing operational compliance under Regulation (EU) 2023/1114.
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- EMT issuance reserved under
- MiCA Art. 48(1)
- EMT rules applicable since
- June 30, 2024
- Redemption at par value
- 1:1
- Electronic money law
- Law 21/2011
Services
MiCA EMT services
Six areas of legal support to launch and operate an e-money token under Title IV of MiCA with legal certainty and operational efficiency.
Authorization
EMI or credit institution license
A strategy to obtain the license needed to issue EMTs, either as an electronic money institution under Law 21/2011 or as a credit institution, with a program of operations, governance and own funds.
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EMILaw 21/2011Bank of SpainPSD2
White paper
EMT white paper under Annex III
Drafting the white paper and notifying it to the Bank of Spain, with the minimum content required by MiCA: holder rights, reserves, redemption, risks and the DTI (ISO 24165).
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White paperAnnex IIIDTIISO 24165
Reserves
Segregation and low-risk assets
Design of the arrangements for funds received: a segregated account with a credit institution and investment in secure, liquid assets denominated in the same reference currency as the EMT.
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SegregationCustodian
Redemption
Right of redemption at par value
Procedures, SLAs and contractual terms to guarantee unconditional redemption to the EMT holder at any time and free of charge.
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RedemptionSLA
AML/CFT
AML, Travel Rule and sanctions
An AML/CFT program as an obliged entity under Law 10/2010, compliance with the TFR and EU/UN/OFAC sanctions screening.
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TFRSEPBLAC
Operations
Recovery and redemption plans
Drafting the mandatory recovery plan and redemption plan, internal governance, marketing policies and ongoing Bank of Spain supervision.
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RecoveryRedemption
Use cases
What an EMT is really for in the EU
EMTs are MiCA’s tool for digitizing fiat money with real backing: payments, treasury, exchange settlement, euro/USD stablecoins and a fiat↔crypto on-ramp with European legal certainty.
Exchanges and CASPs
Settlement and fiat↔crypto on-ramp
"European CASPs can only offer stablecoins that are MiCA-compliant EMTs. Issuer compliance is now a listing and liquidity criterion."
Corporate treasury
On-chain treasury mobility
"EMTs allow corporate treasuries to move tokenized euros between subsidiaries, suppliers and accounts, with traceability and a guaranteed redemption rule."
Regulated DeFi
Productive DLT with a stable base asset
"EMTs can be built into smart contracts for lending, settlement or programmable money, always with the MiCA framework as the legal umbrella."
Consequences
Why does the EMT framework allow no shortcuts?
Since June 30, 2024, only authorized credit institutions or EMIs may issue EMTs in the EU. Without a license and without a white paper notified to the Bank of Spain, the issuance is void and the project is exposed to suspension, delisting and penalties.
Reserved activity: MiCA Art. 48(1) limits the issuance of EMTs to authorized credit institutions and EMIs. Any issuer without a license is outside the perimeter.
Strict supervision by the Bank of Spain: white paper, reserves, redemption, marketing policies, market disclosure and operational continuity.
Ban on remuneration: EMTs may not pay interest to holders merely for holding them, which prevents them from competing directly with bank deposits.
MiCA Art. 23
Non-euro limits
EMTs referencing currencies other than the euro are subject to quantitative limits as a means of payment when they are used on a large scale in the EU.
CASP delisting
ESMA statement
European CASPs may not provide services involving EMTs that do not comply with MiCA: this affects listing, offers to the public and liquidity.
MiCA / Bank of Spain
Suspension
The Bank of Spain may prohibit the offer or admission to trading of the EMT, require advertising to stop and impose penalties on the issuer.
Planning to issue an EMT under MiCA?
We support you from the strategic analysis to the notification of the white paper to the Bank of Spain: EMI license, white paper, reserves, redemption and an ongoing compliance program.
Frequently asked questions
MiCA EMTs: common questions
What is an EMT under MiCA?
An EMT (e-money token) is a type of crypto-asset regulated by Title IV of Regulation (EU) 2023/1114 (MiCA) that purports to maintain a stable value by referencing the value of a single official currency (the euro, the dollar, the pound, etc.).
Functionally, it is the digital representation of electronic money on a distributed ledger. Common examples on the market are USDC, EURC and euro stablecoins issued by authorized European entities.
What is the difference between an EMT and an ART?
An EMT references a single official currency only. An ART (asset-referenced token) maintains its value by referencing a basket of currencies, commodities or assets, or even other crypto-assets.
Both are tokens designed to keep a stable value, but they fall under different frameworks within MiCA: EMTs are governed by Title IV and ARTs by Title III.
Who can issue an EMT in Spain?
Under MiCA Art. 48(1), EMTs may only be issued by authorized credit institutions or electronic money institutions (EMIs) that have published a white paper after notifying it to the Bank of Spain.
In Spain, EMI authorization is obtained under Law 21/2011 of July 26 on Electronic Money, with supervision by the Bank of Spain.
What must an EMT white paper contain?
At a minimum, the white paper must contain: the issuer’s identity, a description of the token, the holder’s rights and obligations, the reserve arrangements, the redemption procedure, risks, the technology framework, the DTI (ISO 24165) and standardized warnings.
It is notified to the Bank of Spain before the offer to the public or admission to trading, in line with Annex III of MiCA.
What reserve requirements does MiCA impose?
The issuer must invest the funds received in secure, low-risk assets in the same reference currency as the EMT, held in separate accounts with a credit institution. Strict custody, segregation and liquidity rules apply.
In addition, MiCA requires recovery and redemption plans to deal with any difficulties the issuer may face.
Do holders always have a right of redemption?
Yes. MiCA guarantees holders the unconditional right to request redemption of their EMTs in fiat currency at par value at any time, and the issuer may not impose abusive fees.
This right is one of the features that set EMTs apart from other crypto-assets, and it must be expressly described in the white paper and the contractual documentation.
Can interest be paid to holders?
No. MiCA expressly prohibits remunerating EMT holders merely for holding the token. The aim is to prevent EMTs from competing with bank deposits and destabilizing the traditional financial system.
Any “yield” scheme on EMTs in the EU must be structured as a separate service (lending, deposits, etc.) with its own license.
What happens to EMTs that do not comply with MiCA?
On January 17, 2025, ESMA published a statement on the provision of certain crypto-asset services in relation to non-MiCA-compliant ARTs and EMTs, urging CASPs to restrict their services involving these assets.
In practice, this means gradual delisting by European exchanges and restricted access to the EU market for stablecoins issued outside the MiCA perimeter.
Practical guide
Practical guide to issuing a MiCA EMT
Issuing an EMT is not about deploying a smart contract. It means obtaining (or already holding) an EMI or banking license, building a defensible reserve model, drafting a white paper in line with Annex III and sustaining an ongoing compliance program before the Bank of Spain.
Applicable legislation
Regulation (EU) 2023/1114 (MiCA) — Title IV; Law 21/2011 on Electronic Money; Directive 2009/110/EC; PSD2 (Directive 2015/2366) and the future PSD3/PSR; the TFR (Travel Rule); Law 10/2010 (AML); ESMA/EBA delegated rules.
Authorization and notification
An EMI license (or a credit institution license) under Law 21/2011, notification of the white paper before issuance, and MiCA’s specific supervision, inspection and sanctions regime for EMT issuers.
What makes the difference
An auditable reserve model, a sound redemption process, a robust AML program and a clear listing strategy with European CASPs are what turn an EMT into a viable market product.
Checklist to launch a MiCA EMT in 10 steps
- Strategic assessment: choose between an EMI (Law 21/2011) and a credit institution, depending on the project’s ambition and scale.
- Prepare and obtain the license as an issuing entity from the Bank of Spain, with adequate capital, governance and resources.
- Design the EMT’s tokenomics: reference currency, chain, supply, mint/burn mechanisms and DTI.
- Structure the reserve arrangements: segregated account, custodian, low-risk assets and proof-of-reserves reports.
- Draft the white paper in line with Annex III of MiCA, with all mandatory information and risk warnings.
- Notify the white paper to the Bank of Spain and handle any requests for information prior to publication.
- Develop the AML/CFT program: KYC, monitoring, Travel Rule and sanctions, aligned with FATF standards.
- Formalize the contractual terms with holders: right of redemption, SLAs, fees and issue resolution.
- Recovery and redemption plans, governance, marketing policies and technology continuity.
- Listing agreements with European CASPs and publication of the white paper after confirmation from the supervisor.
Many EMT projects first test their model in the financial sandbox, which lets them refine the protocol before the final issuance. In ongoing operations, the AML program must build in the FATF lists and, if the managing entity is part of a regulated group, coordinate with the SGIIC or with the independent directors of the investment firm (ESI).
EMTs in practice
From idea to market: the operational anatomy of a MiCA EMT
An EMT project is won on four simultaneous fronts: the issuer’s license, the technical and legal white paper, segregated and auditable reserves, and distribution through European CASPs. This is the operational dashboard we work through with every promoter.
1) LicenseEMI or credit institution
Without the required license, there can be no EMT. Choosing the vehicle, preparing the application to the Bank of Spain and demonstrating governance and capital.
- Law 21/2011
- Minimum capital
- Fit and proper
2) White paperWhite paper + DTI
The EMT’s contractual and transparency document, with the minimum information under Annex III of MiCA, warnings, holder rights and the DTI code (ISO 24165).
- Notification to the Bank of Spain
- Annex III
- DTI ISO 24165
3) ReservesSegregation + redemption
Funds received are invested in secure, low-risk assets and held in separate accounts, with the holder’s right of redemption at par value.
- Independent custodian
- Proof of reserves
- 1:1 redemption
4) DistributionEuropean CASPs and listing strategy
CASPs may only offer MiCA-compliant EMTs. Defining the listing strategy, technical integration, commercial agreements and Travel Rule compliance is decisive for achieving liquidity.
Tip: the ESMA statement on non-compliant EMTs makes MiCA compliance a decisive criterion for European exchanges.
Quick decisionPractical map: EMT, ART or electronic money?
EMT (MiCA Title IV)
References a single official currency. EMI or bank license + white paper.
ART (MiCA Title III)
Basket of currencies, commodities or assets. Specific authorization for the issuer.
Electronic money
Traditional off-chain e-money under Law 21/2011 / Dir. 2009/110/EC. Not tokenized.
EMT playbook
EMT issuer obligations in practice
Required license
Authorization as a credit institution or electronic money institution under Law 21/2011.
Registration with the Bank of Spain, authorization application and approved internal policies.
White paper
Drafted in line with Annex III of MiCA, notified to the Bank of Spain and published.
Registered white paper, notification acknowledgment, published version and updates.
Reserves
Secure, low-risk assets, a separate account with a credit institution, 1:1 ratios.
Custody agreements, portfolio composition, proof-of-reserves reports, audits.
Redemption
The holder’s unconditional right to redemption at par value, without abusive fees.
Published procedure, SLAs, handling channel and log of processed requests.
Marketing
Fair, clear and not misleading communications; risk warnings required by MiCA.
Materials repository, prior legal review, log of marketing pieces and approvals.
AML/CFT
A full program as an obliged entity (Law 10/2010), Travel Rule and sanctions screening.
AML manual, KYC files, alert logs, reports to SEPBLAC.
Typical red flags in an EMT project
Operational indicators that call for a review of the design or the issuer’s profile before issuance.
- An issuer without a credit institution or EMI license that plans to launch a euro "stablecoin" in the EU.
- Opaque "yield" strategies on the EMT balance, seemingly competing with bank deposits.
- Poorly structured reserves, or reserves with no real segregation from the issuer’s balance sheet.
- An incomplete white paper, without a DTI or standardized warnings, or not notified to the Bank of Spain.
- Heavy use of a non-euro EMT as a means of payment in the EU without analyzing the thresholds in MiCA Art. 23.
Practical glossary
Key concepts for working with MiCA EMTs
If you are going to issue, distribute or use an EMT, these terms appear in the MiCA Regulation, in Bank of Spain documentation, in white papers and in agreements with CASPs.
MiCAReg. (EU) 2023/1114
Markets in Crypto-Assets Regulation
The EU regulation that harmonizes the rules on the issuance and offering of crypto-assets and crypto-asset services in the EU. EMTs are governed by Title IV.
Fully applicable since December 30, 2024.
EMTE-Money Token
Electronic money token
A crypto-asset that purports to maintain a stable value by referencing the value of a single official currency, such as the euro or the dollar.
The digital equivalent of electronic money.
ARTAsset-Referenced
Asset-referenced token
A crypto-asset that maintains its value by referencing a basket of currencies, commodities or other assets or crypto-assets.
Title III of MiCA.
EMILaw 21/2011
Electronic Money Institution
A financial institution authorized to issue electronic money and, by extension under MiCA, EMTs. Supervised by the Bank of Spain.
Alternative: a credit institution.
White paperAnnex III
EMT white paper
The issuer’s mandatory transparency document, with minimum content (rights, reserves, risks, DTI) and prior notification to the Bank of Spain.
The issuer’s responsibility.
DTIISO 24165
Digital Token Identifier
The standardized ISO 24165 identifier assigned to each token; MiCA incorporates it as the standard technical reference in regulatory documentation.
Global standard.
RedemptionAt par
Redemption at par value
The unconditional right of an EMT holder to request redemption in fiat currency at par value at any time.
A contractual and regulatory obligation.
MiCA Art. 23Large-scale use
Limits on non-euro EMTs
Quantitative thresholds on the use as a means of payment of EMTs referencing currencies other than the euro, to preserve financial stability and monetary sovereignty.
ECB/EBA/ESMA oversight.
CASPDistribution
Crypto-Asset Service Provider
European crypto-asset service providers authorized under MiCA. CASPs may only deal with MiCA-compliant EMTs.
Key to the EMT’s liquidity.
Contact
Book a call
Tell us about your EMT project and we will explain how to approach the license, the white paper, reserves and your CASP listing strategy to enter the European market on the right footing.
Legal framework for EMTs: MiCA, Law 21/2011 and Bank of Spain supervision
E-money tokens (EMTs) are one of the two types of crypto-assets subject to a stricter regime under Regulation (EU) 2023/1114 (MiCA). As with ARTs, the EMT obligations have applied since June 30, 2024, while the rest of the Regulation became fully applicable on December 30, 2024.
MiCA Regulation, Title IV
Title IV of MiCA governs the issuance, offer to the public and admission to trading of EMTs: reserved activity (Art. 48(1)), white paper content, holder rights, reserve rules, redemption, governance, marketing, recovery and redemption plans, and the sanctions regime.
Reserved activity and license
Under MiCA Art. 48(1), since June 30, 2024 EMTs may only be issued by authorized credit institutions or electronic money institutions (EMIs). In Spain, EMI authorization is governed by Law 21/2011 of July 26 on Electronic Money and its implementing regulations, under the supervision of the Bank of Spain.
White paper and notification to the Bank of Spain
Before offering an EMT to the public or seeking its admission to trading, the issuer must publish a white paper in line with Annex III of MiCA, which is notified to the Bank of Spain. The supervisor may prohibit the offer, require marketing communications to stop or suspend trading in the EMT if it detects breaches.
Reserves, redemption and the ban on interest
The EMT issuer must issue the tokens at par value on receipt of funds, invest those funds in secure, low-risk assets in the same currency as the EMT, hold them in separate accounts and redeem the tokens at the holder’s request at any time. MiCA expressly prohibits paying interest to holders merely for holding the EMT.
Links with PSD2, AML and the TFR
EMT issuance sits within a broader framework: PSD2 (Directive 2015/2366) and the future PSD3/PSR applicable to payment services, Law 10/2010 (AML), the TFR (Travel Rule) and European and international rules on financial sanctions. The issuer is a full AML obliged entity.
CASPs, ESMA and non-compliant EMTs
CASPs (exchanges, custodians, platforms) may only provide services involving MiCA-compliant EMTs. On January 17, 2025, ESMA published a statement on the provision of certain crypto-asset services in relation to non-compliant ARTs and EMTs, narrowing the access of unregulated stablecoins to the European market.
Crypto services and MiCA
Related areas
Resources and blog
Official sources
Key legislation, linked to the official text:
- Law 21/2011 of July 26 on Electronic MoneyBOE · consolidated text
- Regulation (EU) 2023/1114 of May 31, 2023 on markets in crypto-assets (MiCA)EUR-Lex · Official Journal of the EU
- Law 10/2010 of April 28 on the Prevention of Money Laundering and Terrorist FinancingBOE · consolidated text
Legislation and links reviewed in .