EMT
E-Money Tokens (Title IV)
"Stablecoins referencing a single official currency (euro, dollar). Only authorized credit institutions or EMIs may issue them. Examples: USDC, EURC."
MiCA Stablecoins (EMT and ART)
Full legal advice on MiCA stablecoins: EMTs and ARTs under Regulation (EU) 2023/1114, issuer authorization, white papers, reserves, redemption rights, CASP listing and delisting of non-compliant stablecoins.
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- Required reserves
- 100%
- Authorized EMT issuers
- MiCA Art. 48(1)
- Applicable to stablecoins since
- June 30, 2024
- Key legislation
- Reg. (EU) 2023/1114
Services
MiCA stablecoin services
Six areas of legal support for issuers, distributors and CASPs that need to operate with stablecoins under the MiCA framework with regulatory certainty and operational efficiency.
Classification
EMT vs. ART vs. other crypto-asset analysis
Legal classification of the token: is it an EMT stablecoin (Title IV) referencing an official currency, or an ART (Title III) referencing a basket? We determine the right regulatory route.
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EMTARTMiFID IICategorization
Authorization
Stablecoin issuer license
Strategy and handling of the authorization before the Bank of Spain: as an EMI or credit institution (EMTs) or a specific authorization as an ART issuer.
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Bank of SpainEMIAnnex IIAnnex III
White paper
MiCA white paper
Drafting and notification of the white paper: mandatory content, warnings, holder rights, reserves, risks and DTI under the ISO 24165 standard.
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Annex IIIDTI
Reserves
Reserve assets and custody
Design of the reserve portfolio, custody agreements, an investment policy in secure, low-risk assets and a proof-of-reserves framework.
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CustodianProof of reserves
CASP
Listing and non-compliant stablecoins
Support for CASPs on listing policies, delisting of non-MiCA-compliant stablecoins and application of the ESMA statement of January 17, 2025.
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ListingSell-only
AML/CFT
AML, Travel Rule and sanctions
AML/CFT program for issuers and CASPs, Travel Rule (TFR) compliance, sanctions screening and policies aligned with the FATF lists.
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TFRSEPBLAC
Categories
Not all "stablecoins" are equal under MiCA
MiCA drops the word "stablecoin" from its legal texts and replaces it with two strict categories: EMTs and ARTs. The applicable regime, the supervisor and the requirements change depending on the category. Algorithmic stablecoins without real backing are left out.
ART
Asset-Referenced Tokens (Title III)
"Stablecoins referencing a basket of currencies, commodities, other assets or crypto-assets. A specific regime, a dedicated authorization and stricter controls."
Algorithmic
Unbacked: not a "stablecoin"
"Algorithmic stablecoins without real backing cannot be called stablecoins in the EU. MiCA requires backing by real reserves held by an independent custodian."
Non-compliant
Stablecoins outside MiCA
"Tokens issued without an EU license: gradual delisting from EU CASPs, sell-only orders and restricted services following the ESMA statement of January 17, 2025."
Consequences
Why is MiCA redrawing the map for stablecoins?
Since June 30, 2024, stablecoins in the EU have needed a license, a notified white paper and auditable reserves. Those who do not comply are shut out of the European market: delisting from exchanges, card restrictions and payment limitations in the euro area.
Reserved activity for EMTs (MiCA Art. 48(1)): only authorized credit institutions or EMIs may issue them. ARTs require a specific authorization from the Bank of Spain.
Reserves equal to 100%, with publication of audited reports. Secure, low-risk assets held in separate accounts.
Unconditional right of redemption at par value, at any time and without abusive fees, except as expressly provided in the white paper.
MiCA Art. 23
Non-euro cap
Quantitative limits on the use as a means of payment of stablecoins referencing currencies other than the euro once they reach systemic volumes.
ESMA Jan. 17, 2025
Sell-only
Statement on services relating to non-MiCA-compliant ARTs and EMTs: gradual delisting, sell-only orders and a ban on mass marketing.
EU market 2026
38 issuers
As of April 2026, there is a consolidated market of authorized issuers (all EMTs). Without an EU license, access to the EU market is practically unfeasible.
Do you have a stablecoin project for the EU market?
We help you classify the token (EMT or ART), prepare the license application before the Bank of Spain, draft the white paper and build the reserve and redemption model that MiCA requires.
Frequently asked questions
MiCA stablecoins: common questions
What is MiCA and how does it affect stablecoins?
MiCA is Regulation (EU) 2023/1114 of May 31 on markets in crypto-assets. It is the first harmonized European framework for crypto-asset issuers and service providers.
For stablecoins, MiCA is decisive: it introduces two strict categories (EMTs and ARTs) with licensing, reserve, white paper and redemption requirements. Non-compliant stablecoins see their access to the EU market restricted.
What is the difference between an EMT and an ART?
An EMT references its value to a single official currency (the euro or the dollar, for example). It can only be issued by authorized credit institutions or EMIs and is governed by Title IV of MiCA.
An ART references its value to a basket of currencies, commodities or assets. It requires a specific authorization from the Bank of Spain under Title III of MiCA, with stricter governance and reserve requirements.
Since when have the MiCA rules on stablecoins applied?
The rules on EMTs and ARTs (Titles III and IV of MiCA) have applied since June 30, 2024. The rest of the Regulation (including the general regime for CASPs) has applied in full since December 30, 2024.
In Spain, the transitional period for existing CASPs has been extended until June 30, 2026.
Which stablecoins comply with MiCA today?
Only those issued by entities authorized in the EU (a credit institution or EMI for EMTs) with a white paper notified to the competent authority. Circle’s USDC and EURC are examples of compliant EMTs. Tether’s USDT has not obtained an EMT license and is considered non-compliant.
The market is reorganizing: as of April 2026, there were 38 authorized issuers in the EU, all of them issuing EMTs.
What obligations do issuers have?
Stablecoin issuers must: (i) be set up as an authorized legal entity; (ii) publish a white paper in line with Annex III of MiCA; (iii) maintain reserves at 100%; (iv) guarantee the right of redemption; (v) comply with governance, marketing, AML and recovery plan requirements; (vi) publish periodic audited reports.
Can interest be paid on the balance?
No. MiCA expressly prohibits remunerating EMT (and ART) holders merely for holding the token, to prevent stablecoins from competing with bank deposits and destabilizing the financial system.
Any "yield" on stablecoins in the EU must be structured as a separate service (lending, deposits, etc.) with its own license.
What do CASPs do with non-compliant stablecoins?
The ESMA statement of January 17, 2025 on the provision of services in relation to non-compliant ARTs and EMTs has led to the gradual delisting of stablecoins without MiCA authorization and to "sell-only" modes that allow existing positions to be closed out.
This is radically reshaping European stablecoin liquidity around authorized issuers.
What role does the Bank of Spain play?
In Spain, the Bank of Spain is the competent authority to authorize and supervise EMT and ART issuers. The CNMV is competent for CASPs and for Title II crypto-assets.
Issuers must notify the white paper to the Bank of Spain and respond to its requests for information on reserves, marketing and recovery plans.
Practical guide
Practical guide to MiCA stablecoins for issuers and CASPs
Operating with stablecoins in Europe requires three decisions: how the token is classified (EMT or ART), who the authorized issuer is and which CASPs distribute it. Without those three pillars, the project does not reach the EU market.
Applicable legislation
Regulation (EU) 2023/1114 (MiCA) — Titles III and IV; Law 21/2011 on Electronic Money; Directive 2009/110/EC; Regulation (EU) 2023/1113 (TFR / Travel Rule); Law 10/2010 (AML); technical standards from ESMA, the EBA and the ECB.
Bank of Spain, CNMV, ESMA and EBA
The Bank of Spain authorizes and supervises EMT and ART issuers. The CNMV supervises CASPs and Title II crypto-assets. ESMA and the EBA coordinate uniform application across the EU.
What makes the difference
A well-classified project, a licensed issuer, a solid white paper, auditable reserves and a listing strategy with authorized CASPs. That is what separates viable stablecoins from those left out.
MiCA stablecoin checklist in 10 steps
- Legal classification of the token: EMT (a single currency), ART (basket) or MiFID II financial instrument?
- Strategic assessment of the vehicle: EMI/bank for EMTs or a specific ART authorization from the Bank of Spain.
- Tokenomics design: reference currency or basket, supply, mint/burn, reserves and DTI code (ISO 24165).
- Building the reserve model: composition, custodians, investment policy and proof of reserves.
- Drafting the white paper in line with Annex III of MiCA, with holder rights, risks and warnings.
- Notification to the Bank of Spain, handling of prior requests for information and publication once cleared.
- AML/CFT program: KYC, monitoring, Travel Rule and sanctions, aligned with the FATF lists.
- Marketing and communications: prior legal review, standardized warnings and a campaign log.
- Distribution strategy: agreements with European CASPs, technical integration and listing policies.
- Ongoing compliance: audited reports, recovery and redemption plans, Bank of Spain/ESMA supervision.
The day-to-day side of single-fiat-currency stablecoins is covered in detail in MiCA EMTs. Many projects first test their model in the financial sandbox and, once operating, must build the FATF lists into their AML program. If the issuer group includes securities market activity, it is worth reviewing the flows with an SGIIC or the role of the independent director of an investment firm (ESI).
Stablecoins in practice
MiCA stablecoins on four simultaneous fronts
A European stablecoin project is decided on four fronts that move at the same time: the legal classification of the token, the issuer’s license, reserves and redemption, and distribution through authorized CASPs. This is the dashboard we apply to every case.
1) ClassificationEMT, ART or MiFID II
The initial decision on the token’s category shapes the entire architecture: competent supervisor, requirements and authorization route.
- One currency → EMT
- Basket → ART
- Tokenized share/bond → MiFID II
2) License + WPAuthorization + white paper
Without an authorized issuer and a white paper notified to the Bank of Spain, there is no stablecoin under MiCA. Both fronts must be coordinated from the start.
- EMI/bank for EMTs
- ART authorization
- Annex III
3) Reserves100% reserves + redemption
Safe, liquid assets, independent custodians, segregation from the issuer’s balance sheet and a right of redemption at par value.
- 1:1
- Independent custodian
- Redemption at par
4) DistributionCASPs, listing and delisting
CASPs may only offer MiCA-compliant stablecoins. The ESMA statement of January 17, 2025 has led to delisting and "sell-only" modes for non-compliant assets.
Tip: listing on regulated CASPs is not just distribution; it is operational proof of MiCA compliance.
Quick decisionPractical map: what type of stablecoin do I have?
EMT
A single fiat currency. Fast track: EMI or bank license + white paper.
ART
Basket or commodities. Specific ART authorization, enhanced governance.
Non-compliant
No EU license: delisting from CASPs, sell-only and no EU passport.
MiCA playbook
Comparison: stablecoin issuer vs. unauthorized player
Access to the EU market
EU passport through the authorized CASP: full liquidity and distribution.
Gradual delisting, sell-only orders, no mass distribution on EU CASPs.
Supervision
Bank of Spain (issuer) and CNMV/ESMA (CASPs). Clear, predictable rules.
No clear European framework; high regulatory and reputational risk.
Reserves
100% in safe, liquid assets, independent custodian, audited reports.
No harmonized European obligations; quality of backing not guaranteed.
Redemption
Unconditional right at par value, at any time, without abusive fees.
Redemption subject to the issuer’s contractual terms, without MiCA protection.
Marketing
Reviewed, accurate communications; standardized MiCA risk warnings.
Possible supervisory requests to stop advertising in the EU.
Corporate treasury
Growing acceptance as a digital treasury tool with regulatory backing.
Compliance risk, especially for AML obliged entities.
Red flags in stablecoin projects
Indicators that call for a review of the design or the issuer’s profile before dealing with the stablecoin.
- A promoter without an EU credit institution or EMI license seeking to issue an EMT marketed as a "euro stablecoin".
- Promises of "yield" on the token balance, seemingly competing with bank deposits.
- A token with "algorithmic" backing and no real reserves under independent custody.
- No white paper in line with Annex III of MiCA, or no notification to the Bank of Spain.
- CASPs that keep listing non-compliant stablecoins despite the ESMA statement of January 17, 2025.
Practical glossary
Key MiCA stablecoin concepts
If you are working on a stablecoin project aimed at the EU market, these are the concepts that appear in MiCA, in CNMV and Bank of Spain documentation, and in agreements with CASPs.
MiCAReg. (EU) 2023/1114
Markets in Crypto-Assets Regulation
The EU regulation governing the issuance and offering of crypto-assets and crypto-asset services in the EU. Stablecoins are governed by Titles III and IV.
Fully applicable since December 30, 2024.
EMTTitle IV
E-Money Token
A stablecoin referencing a single official currency (euro, dollar). Only issuers authorized as a credit institution or EMI.
Examples: USDC, EURC.
ARTTitle III
Asset-Referenced Token
A stablecoin referencing a basket of currencies, commodities or assets. Specific authorization from the Bank of Spain.
Enhanced governance regime.
CASPCNMV
Crypto-Asset Service Provider
A European crypto-asset service provider authorized under MiCA. It may only offer compliant stablecoins.
EU passport after authorization.
White paperAnnex III
Crypto-asset white paper
The issuer’s mandatory document setting out holder rights, reserves, risks, the DTI and standardized warnings.
Notified to the competent authority.
Reserves1:1
Backing assets
Secure, low-risk assets in the reference currency, held in separate accounts, with audited reports.
Periodic proof of reserves.
RedemptionAt par
Redemption at par value
The holder’s right to exchange the token for fiat currency at par value at any time.
No abusive fees.
ESMA statementJan. 17, 2025
Non-compliant stablecoins
Statement on the provision of services relating to non-MiCA-compliant ARTs and EMTs: delisting and sell-only orders.
Applied by EU CASPs.
DTIISO 24165
Digital Token Identifier
A standardized token identifier. A mandatory ISO standard for the regulatory traceability of crypto-assets.
Accounting and supervisory documentation.
Contact
Book a call
Tell us about your stablecoin project and we will explain how to approach classification, licensing, the white paper, reserves and CASP listing to enter the European market on the right footing.
Legal framework for MiCA stablecoins: EMTs, ARTs and European supervision
Stablecoins in the European Union no longer operate in a gray area: Regulation (EU) 2023/1114 of May 31 on markets in crypto-assets (MiCA) provides the harmonized legal framework, with strict rules for issuers and for the CASPs that distribute them.
When MiCA applies to stablecoins
The stablecoin rules (Title III – ARTs and Title IV – EMTs) have applied since June 30, 2024. The rest of the Regulation has applied since December 30, 2024. In Spain, the transitional period for existing CASPs runs until June 30, 2026.
Regulated categories: EMTs and ARTs
MiCA splits stablecoins into two strict categories. EMTs are crypto-assets that purport to maintain a stable value by referencing a single official currency (the euro or the dollar, for example). ARTs are crypto-assets that purport to maintain a stable value by referencing a basket of currencies, commodities or assets. The choice of category determines the applicable regime, the competent supervisor and the authorization requirements.
Reserved activity and license
EMTs may only be issued by authorized credit institutions or EMIs (MiCA Art. 48(1)), under Law 21/2011 on Electronic Money. ARTs require a specific authorization from the Bank of Spain, with an enhanced regime for governance, capital and reserves.
White paper and notification to the supervisor
Before the offer to the public or admission to trading, the issuer must publish a white paper in line with Annex III of MiCA, covering holder rights, a description of the token, reserves, risks, the DTI (ISO 24165) and standardized warnings. It is notified to the Bank of Spain, which may prohibit the offer or require marketing communications to stop if it detects breaches.
Reserves, redemption and the ban on interest
Issuers must maintain reserves equal to 100% in secure, low-risk assets, held in separate accounts, with periodic audited reports. Holders have an unconditional right of redemption at par value at any time. MiCA prohibits remunerating holders merely for holding the token.
CASPs, ESMA and non-compliant stablecoins
European CASPs may only provide services involving MiCA-compliant stablecoins. The ESMA statement of January 17, 2025 on the provision of certain services in relation to non-compliant ARTs and EMTs has led to gradual delisting, "sell-only orders" and limits on marketing stablecoins issued outside the MiCA perimeter, completely reshaping European liquidity in this market.
Crypto services and MiCA
Related areas
Resources and blog
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
- Law 21/2011 of July 26 on Electronic MoneyBOE · consolidated text
- Directive 2009/110/EC of September 16, 2009 on the taking up and pursuit of the business of electronic money institutionsEUR-Lex · Official Journal of the EU
Legislation and links reviewed in .