Issuing a stablecoin in the European Union is a regulated-entity project before it is a technology project. This page does not explain what MiCA says about stablecoins. It explains the four real routes to bring one to market, what each one requires, how an issuer that cannot pay interest stays economically viable, and what it takes to get someone to list it.
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“Stablecoin” is not a legal category. MiCA does not use it. What exists are e-money tokens and asset-referenced tokens, and the difference between them decides who can issue them, before which supervisor and through which application. Almost every project that comes to our firm has chosen its technical architecture before answering this question, and that is exactly the worst way to start.
The full EMT and ART regime under Regulation (EU) 2023/1114: obligations, supervision and how it fits in the EU framework. If you are looking for the legal framework rather than the project, start there.
MiCA stablecoins → Token typeThe stablecoin that references a single official currency. It is the route taken by the vast majority of European projects, and the one that requires a banking or e-money license.
EMTs under MiCA → Token typeThe token that references a basket, another value or several assets. It requires a specific authorization under MiCA and a considerably heavier application.
ARTs under MiCA →Becoming an authorized issuer is not the only way to have a stablecoin on the market, and in many projects it is not the best one. Before budgeting for a license, put all four options on the table and decide on business grounds, not by default.
| Route | What it involves | When it makes sense | Relative cost |
|---|---|---|---|
| Your own e-money license | Obtain authorization as an electronic money institution from the Bank of Spain and issue the EMT as an authorized institution, with a notified white paper. | The token is the product, and control over the reserve, the brand and the financial returns is part of the business model. | High |
| Issuance as a credit institution | An already authorized bank issues the token under its own license, with the additional obligations that MiCA imposes on the issuer. | Banking groups, or projects with a banking partner willing to commit its license and its balance sheet. | Variable |
| Third-party authorized issuer | An already authorized issuer issues the token in its own name, and your project distributes or integrates it. You are not the issuer. | The token is a means for your product (payments, settlement, treasury), not an end in itself. It is the fastest route to market. | Low |
| Specific ART authorization | Apply for the authorization under Article 16 of MiCA to issue a token that references a basket or assets other than a single official currency. | The design requires referencing several currencies, commodities or a basket, and it cannot be reworked as an EMT. | Very high |
The third route is missing from almost every business plan we review, and yet it is the one that solves most use cases: if what you need is to settle in digital euros within your product, you do not necessarily need to be the one issuing them.
A stablecoin project moves forward on six workstreams at once. The one that usually lags behind is neither the legal nor the technical one: it is distribution, and it decides whether the token exists or remains a deployed smart contract that nobody uses.
Preparing the electronic money institution application before the Bank of Spain or, if the design requires it, the specific authorization for an asset-referenced token. This includes the program of operations, the governance structure and evidence of fitness and propriety.
The document that allows the token to be offered to the public and service providers to list it. Mandatory content, marketing communications consistent with it, and notification to the supervisor with the required advance notice before publication.
Composition, custody, segregation, investment policy and reconciliation. It is the workstream that underpins the right of redemption, and the one the supervisor examines most closely.
Without authorized platforms to trade it, hold it in custody or exchange it, a stablecoin reaches no users. We prepare the package that a European CASP asks for before listing a token.
An AML manual adapted to on-chain operations, sanctions screening of addresses and transaction monitoring. An issuer is an obliged entity from day one.
Notification to operate in other Member States, and preparation for crossing the thresholds that make a token significant and move supervision to the EU level.
The critical dependency comes first, and almost nobody respects it: the classification of the token determines the license, and the license determines the entire timeline. Developing the smart contract before deciding whether the project is an EMT or an ART is building from an unsigned blueprint.
From the product idea to the first user who can buy the token on an authorized platform.
The economic design is analyzed (what it references, what rights it confers, how it is stabilized) to determine whether it is an e-money token, an asset-referenced token, another crypto-asset or simply a financial instrument outside the scope of MiCA. Everything else depends on this answer.
Deciding between your own license, a banking partner, a third-party issuer or ART authorization. This is where the real investment in the project is sized and where you decide whether the token is the product or only the infrastructure for another product.
If the chosen route requires your own license, the application is prepared for the Bank of Spain: program of operations, corporate governance, fit and proper senior management, technical resources, capital and safeguarding of funds. It is the longest workstream of the project.
Composition of the reserve, custodian institutions, segregation from the issuer’s own assets, a conservative investment policy and a reconciliation procedure. This is what makes redemption enforceable, and what is then audited on a recurring basis.
Drafting the white paper with the mandatory content, notifying it to the supervisor with the required advance notice before publication, and checking that all marketing communications are consistent with it. Marketing material that promises a return contradicts the white paper itself.
An AML manual adapted to blockchain operations, sanctions screening of addresses, transaction monitoring, a freezing policy and an end-to-end operational redemption procedure.
Agreements with crypto-asset service providers to trade and hold the token, with market makers, and with the banks that will hold the reserve and support subscription and redemption flows. It starts long before authorization, and it is the phase that most projects underestimate.
It is the most widespread confusion in the sector, and it has immediate practical consequences: some projects spend months talking to the wrong supervisor. In Spain, token issuance and crypto-asset services are in the hands of two different authorities.
| Entity | Authority | Scope |
|---|---|---|
| Issuer of e-money tokens (EMT) | Bank of Spain | Authorization as an electronic money institution or credit institution, white paper notification, and supervision, inspection and sanctioning of the issuer. |
| Issuer of asset-referenced tokens (ART) | Bank of Spain | Specific authorization under Article 16 of MiCA, or approval of the white paper when the issuer is a credit institution. |
| Crypto-asset service provider (CASP) | CNMV | Authorization and supervision of firms that trade, hold in custody, exchange or advise on crypto-assets. |
| Issuances of other crypto-assets (Title II) | CNMV | Offers to the public and admission to trading of crypto-assets other than EMTs and ARTs. |
| Significant tokens | European Banking Authority | EU-level supervision when the token exceeds the thresholds for size, number of holders or transaction volume. |
| Anti-money laundering | SEPBLAC | The issuer’s obliged-entity regime, with a manual, a risk assessment and a designated representative. |
A point on timing that many sources still get wrong: Spain initially announced a twelve-month transitional period for service providers, but in the end applied the full eighteen-month period allowed by Article 143(3) of MiCA, which ended on July 1, 2026. That transitional period applied to service providers, not to token issuers.
It is the question most often avoided in the business plans we review. MiCA prohibits the issuer (and those who distribute the token) from granting interest to holders simply for holding it, and it also prohibits linking remuneration to the holding period. That wipes out the most obvious commercial argument at a stroke and forces you to build the model elsewhere.
| Source | How it works | Limit imposed by MiCA |
|---|---|---|
| Return on the reserve | The funds received are held in deposits and in high-quality liquid assets, which generate a return for the issuer. | The investment policy is conservative by regulatory requirement, and part of the funds must remain in deposits with credit institutions. The return cannot be passed on to holders. |
| Subscription and redemption fees | Charging to convert official currency into tokens and back, usually to wholesale clients or distributors. | Redemption is a right of the holder and must be honored on terms that do not render it meaningless. |
| Related services | Payment infrastructure, settlement, treasury, merchant integration and developer tools built around the token. | If any of those services is on the list of crypto-asset services, the corresponding authorization is also required. |
| Brand licensing and distribution | Agreements with platforms, merchants or institutions that integrate the token into their product. | Distributors cannot offer interest for holding the token either: the commercial design must respect this downstream. |
| Float and economies of scale | The model only works above a volume of tokens in circulation large enough for the return on the reserve to cover the structure. | Reaching that volume depends on distribution, not on the license. It is the real risk of the project. |
The practical conclusion is uncomfortable, but it is better to accept it before investing: your own stablecoin is rarely profitable as a stand-alone product. It is profitable when it solves a bottleneck in an existing business (cross-border payments, settlement between platforms, group treasury) and when a distribution channel is secured from the start.
The risks of an issuance project are not the ones that show up in the legal analysis. They are operational, commercial and reputational, and almost all of them materialize after launch.
Offering an e-money token to the public in the Union without being an authorized credit institution or electronic money institution, or an asset-referenced token without the corresponding authorization, exposes the project to supervisory action and an immediate commercial standstill.
Authorized European providers only list compliant tokens. A token with no notified white paper and no authorized issuer has nowhere to trade, and without trading there is no liquidity and there are no users.
The right of redemption at par is exercised precisely when it hurts the issuer most: during a stress episode. A reserve with illiquid or poorly segregated assets turns a confidence problem into a solvency problem.
Promising a return, suggesting price appreciation or presenting the token as an investment clashes with the ban on granting interest and with the consistency required between marketing communications and the white paper.
An issuer needs banks willing to hold deposits linked to a crypto-asset business. It is a long negotiation, with its own source-of-funds and control requirements, and it blocks the project even when the license has been granted.
Success brings its own problem: exceeding the thresholds for size, holders or volume moves supervision to the EU level and adds enhanced requirements. Plan for it from the outset rather than discovering it after it has happened.
We analyze the use case, classify the token, compare the four routes with their cost and timeline, and tell you which one fits. Sometimes the answer is a license; sometimes it is an agreement with an issuer that already has one.
REGULATORY CONTROL CENTER · ISSUANCE PROJECT
A bank that wants to tokenize deposits, a payment institution extending its license and a crypto platform that wants its own digital euro face the same framework with different problems. This panel shows where to focus your team from the first week.
An indicative reference for sizing the project and deciding what to build in-house and what to source from third parties.
None of them is a misreading of the rules. They are all mistakes of sequencing or of business planning.
Writing the smart contract, choosing the chain and finalizing the tokenomics before determining whether the project is an EMT or an ART. Classification determines the license, the supervisor and much of the economic design: doing it afterwards means redoing work.
Most of the use cases we see (settling between platforms, paying suppliers, moving treasury) can be solved by integrating an already authorized token. Becoming an issuer only pays off when the token is the product.
Entire business plans rely on sharing the reserve’s return with token holders. That route is closed: neither the issuer nor those who distribute the token may grant interest for merely holding it.
Negotiating with platforms, market makers and banks takes months, and they have their own risk committees. If it starts on the day authorization arrives, the token is born without liquidity and with the investment clock already running.
It is a regulatory document with mandatory content, subject to prior notification to the supervisor and to rules on how it may be amended. Having the communications team draft it and then sending it for legal review reverses the correct order.
The right of redemption at par must work end to end: identifying the requester, verification, conversion and payment, with set timeframes and the capacity to handle peaks. It is an operational process, not a clause in the white paper.
Three principles that separate projects that reach the market from those that end up as an expensive proof of concept.
The first decision in the project is legal, not technical. Determining whether the token is an e-money token or an asset-referenced token sets the supervisor, the license, the capital and the timeline. Everything else hangs on that.
Your own license, a banking partner, a third-party issuer or ART authorization. Each has a different cost, timeline and degree of control. The decision should be based on an explicit comparison, not on inertia toward the most ambitious option.
Talks with platforms, banks and the first institutional users must start while the application is being processed. An authorized issuer without a distribution channel has an expensive license and no business.
If you want to test the feasibility of your issuance, see our crypto-asset services or request a free consultation.
Terms that come up in every project meeting. Product, technology and legal teams should use them with the same meaning from day one, because several of them are used in the industry with a different meaning from the one they have in the legislation.
MiCA does not use it. What it regulates are e-money tokens and asset-referenced tokens. Calling a project a “stablecoin” says nothing about its regime.
A crypto-asset that purports to maintain a stable value by referencing a single official currency. Under Article 48(1) of MiCA, only authorized credit institutions or electronic money institutions may issue it.
A token that seeks stability by referencing another value or right, or a combination of them, including baskets of currencies. It requires the specific authorization under Article 16 of MiCA.
The funds and assets that back the tokens in circulation and make redemption possible. It must be segregated from the issuer’s own assets, held in custody and managed on conservative criteria.
The holder’s right to recover the value of the token from the issuer at any time and at par. It is not a commercial promise: it is an obligation with operational consequences for capacity and timeframes.
A document with mandatory content that allows the token to be offered to the public. It is notified to the supervisor before publication and governs all subsequent marketing communications.
Neither the issuer nor those who distribute the token may grant interest to holders for holding it, or link any benefit to the holding period.
A category triggered when thresholds for number of holders, value issued or transaction volume are exceeded. It moves supervision to the EU level and adds enhanced requirements.
A firm authorized to trade, hold in custody, exchange or advise on crypto-assets. Without agreements with these players, an issued token does not reach any end user.
Yes, unless the route you choose is to rely on an issuer that already has one. If the token references a single official currency, Article 48(1) of MiCA reserves its issuance to authorized credit institutions and electronic money institutions. If it references a basket or other assets, you need the specific authorization under Article 16.
There is no stand-alone “stablecoin license”: what you obtain is the status of an authorized institution, and on that basis the token is issued with its white paper.
The Bank of Spain. It is the competent authority for the issuance of asset-referenced tokens and e-money tokens, and its electronic office offers the pre-notification and application procedures. The CNMV, by contrast, handles crypto-asset service providers and Title II issuances.
It is a common and costly confusion: some projects spend months in dialogue with a supervisor that is not the right one for them.
The reference. An EMT keeps its value stable against a single official currency (a private digital euro, for example). An ART references anything else: a basket of currencies, commodities, other assets or a combination.
The practical consequence is significant: an EMT requires being a credit institution or an electronic money institution; an ART requires its own authorization under MiCA, with a considerably more demanding application and requirements. We cover this in detail in EMTs under MiCA and ARTs under MiCA.
No. MiCA prohibits the issuer from granting interest for holding the token, and extends the ban to those who distribute it. Nor can you offer benefits linked to how long the token is held.
This forces you to build the business model elsewhere: the issuer keeps the return on the reserve, and additional revenue comes from fees and from the services built around the token. We break this down in the section on project economics.
Yes, and in many projects it is the best decision. You can integrate into your product a token issued by an already authorized institution, under distribution or branding agreements. You will not be the issuer, so you do not take on that regulatory burden, but you may become subject to other obligations if you provide crypto-asset services.
It is the fastest route to market and the one that ties up the least capital. It is worth comparing it with the other three before deciding.
It is the document with mandatory content that allows the token to be offered to the public and admission to trading to be sought. It is notified to the supervisor before publication, with the advance notice required by the Regulation, and all subsequent marketing communications must be consistent with it.
It is not an investor fundraising document in the style of the initial coin offerings of the previous era. Treating it that way is a sure source of problems. We cover it in detail in crypto-asset white paper.
It depends entirely on the route. Relying on an authorized issuer involves integration costs and commercial agreements. Obtaining your own e-money license involves regulatory capital, a governance structure, control functions, technical resources and an application process lasting months. Authorization for an asset-referenced token is the most demanding of the four.
The cost that almost nobody budgets for, and which is often decisive, is distribution: getting platforms, banks and institutional users to adopt the token.
Yes. MiCA is built on the passporting principle: once authorization is obtained in one Member State, the activity can be extended to the others by notification, without needing a new authorization in each country.
If expansion is part of the plan, it should be built into the program of operations from the start. We cover it in MiCA passporting.
It changes regime. Once certain thresholds for number of holders, value issued or transaction volume are exceeded, the token is considered significant and supervision moves to the EU level, with enhanced requirements on the reserve, governance and risk management.
It is a scenario worth modeling in the business plan, because the jump is not gradual: it happens when the threshold is crossed.
No. Spain initially announced a twelve-month transitional period, but in the end applied the full eighteen months allowed by Article 143(3) of MiCA, which ended on July 1, 2026. Many sources still get this wrong.
It is also important not to mix things up: that regime applied to crypto-asset service providers that were already operating, not to token issuers. To issue today, you must be authorized. We cover this in the transition from VASP to CASP.
Everything stated on this page comes from Regulation (EU) 2023/1114 or from documents published by the supervisors. These are the primary links to check it without intermediaries.
The authentic Spanish text of the Regulation on markets in crypto-assets, with its European Legislation Identifier. Articles 16 and 48 set out who may issue ARTs and EMTs.
eur-lex.europa.eu/eli/reg/2023/1114/oj Bank of SpainThe supervisor’s electronic office page, with details of the procedure, the pre-notification forms and the recommendation to get in touch before starting the formal procedure.
sedeelectronica.bde.es · MiCAR CNMVAllocation of powers between the CNMV and the Bank of Spain, the regime for crypto-asset service providers and the status of the Regulation’s application in Spain.
cnmv.es · MiCA portal CNMVThe Spanish supervisor’s guidance document on the practical application of the Regulation, useful for resolving questions about how a project fits before raising them formally.
cnmv.es · MiCA FAQ (PDF) EUR-LexA summary prepared by the European Union: categories of crypto-assets, issuer obligations, the regime for significant tokens and the application timeline.
eur-lex.europa.eu · summary BOEThe Spanish law that regulates electronic money institutions, the type of entity on which e-money token issuance relies in Spain.
boe.es · BOE-A-2011-12909The crypto-asset framework moves fast, and an outdated guide costs anyone who follows it months. That is why we publish who maintains it and with what method.
Tell us what your token references, what you need it for and who will use it, and we will tell you what you are for MiCA purposes and which of the four routes suits you.
For years, launching a stablecoin was an engineering exercise. With Regulation (EU) 2023/1114 it became an authorization exercise: the technical part is still necessary, but it is no longer the hard part. Today, in the European Union, the relevant question is not which chain you choose or how you design the stabilization mechanism, but who is authorized to issue what you want to issue.
MiCA does not recognize the term “stablecoin”. It regulates e-money tokens (those that reference a single official currency) and asset-referenced tokens (those based on a basket, other values or several assets). Article 48(1) reserves the issuance of the former to authorized credit institutions and electronic money institutions; Article 16(1) makes the latter subject to a specific authorization. That split decides the supervisor, the capital, the application and the timeline, and it is why classifying the token must be the first task of the project, not a later review.
MiCA prohibits granting interest to holders simply for holding the token, and extends that ban to those who distribute it. This removes the most obvious commercial lever, and the model has to rest on the return on the reserve, on subscription and redemption fees, and on the services built around the token. Since the return on the reserve depends on the volume in circulation, and volume depends on distribution, the real risk of the project is not regulatory: it is commercial. Authorized issuers with a flawless license and no channel do exist, and they are not a good business.
In Spain, supervision of issuers of asset-referenced tokens and e-money tokens lies with the Bank of Spain, which offers pre-notification and application procedures on its electronic office and recommends getting in touch before starting the formal procedure. The CNMV handles crypto-asset service providers and Title II issuances. Confusing the two costs months of wasted dialogue, and it happens more often than you might expect.
The transitional period that allowed already registered service providers to keep operating ended on July 1, 2026: in the end, Spain applied the full eighteen-month period under Article 143(3), not the twelve months it had initially announced. For an issuer, this matters for an indirect but decisive reason: the platforms that can list and distribute its token are now all authorized entities, with risk committees and their own documentation requirements. Getting into that circuit is as decisive for the project’s success as obtaining the license itself.
Key legislation, linked to the official text:
Legislation and links reviewed in .