The sort in Section 2 told you what a stabilising token is; this section is what that verdict costs the people behind it. By the end you can say who may issue each kind of stablecoinA token designed to track a currency, run by an issuer who can typically freeze balances — e.g. USDT or USDC., name the machinery — own fundsThe firm's own capital — the money that absorbs losses before anyone else's. MiCA sets floors and can require more., the reserve, redemption — and explain why the live market has filled one title and left the other empty.
In one screen · section 4 of 9
The whole regime, one map — this section's territory is lit; every section lights its own.
StablecoinsA token designed to track a currency, run by an issuer who can typically freeze balances — e.g. USDT or USDC. get MiCA's heaviest machinery: authorisation, own fundsThe firm's own capital — the money that absorbs losses before anyone else's. MiCA sets floors and can require more., a reserve of assetsThe pool an asset-referenced token issuer must hold so the token can always be redeemed. Its composition and liquidity are regulated separately from the issuer's own money., redemption rights, and — for the significant ones — direct EBAThe European Banking Authority — ESMA's banking-side sibling, responsible for MiCA's stablecoin rulebook. It drafts; the Commission adopts. supervision.
The two titles are asymmetric by design: an e-money token may only be issued by a credit institution or e-money institution, while the asset-referenced title builds a bespoke authorisation — and the live market has embraced one and not the other.
And the section's second half is the issuer's own operating stack: the capital floors, the reserve and its liquidity, the bad-day plans, governance, and the thresholds where supervision moves to the EBA.
Why do stablecoins get the heaviest rules?
Because of the promise. A token that purports to hold a stable value invites people to treat it like money — and anything treated like money can suffer a run. The whole architecture of Titles III and IV answers that one risk: someone identifiable must stand behind the promise, hold real assets against it, and give every holder a way out at full value, at any time. These were also the first parts of MiCA to bite, applying from 30 June 2024 — six months before the rest.
Check yourself
Nordwind, from the gallery, is used by millions as a store of value. Why does it escape this section's machinery entirely?
ARTs: the bespoke authorisation title
Nobody may offer an asset-referenced token to the public, or seek its listing, unless they are its issuer and either an EU legal person authorised for exactly this, or a credit institution using its banking licence as the door. Two narrow escapes exist — an average outstanding value that never exceeds €5 million, or an offer held only by qualified investors — and even the exempt still write and notify a white paperThe disclosure document MiCA requires before most crypto-assets are offered to the public or admitted to trading — contents prescribed, liability attached, notified to the regulator..
The authorised carry the machinery. Own fundsThe firm's own capital — the money that absorbs losses before anyone else's. MiCA sets floors and can require more.: at all times the highest of €350,000, 2% of the average reserve, or a quarter of last year’s fixed overheads. A reserve of assetsThe pool an asset-referenced token issuer must hold so the token can always be redeemed. Its composition and liquidity are regulated separately from the issuer's own money., segregated and managed under its own rules, backing the tokens one-for-one in substance. A permanent right of redemption: any holder, at any time, paid in funds or in the referenced assets themselves. And plans for the bad days — recovery and redemption plans, drawn up before they are needed.
Grow large enough and the supervisor changes. An ARTAsset-referenced token — a crypto-asset claiming to hold a stable value by referencing anything other than exactly one official currency: a basket, gold, another asset. MiCA checks e-money tokens first; ART is the stablecoin residual (Title III). becomes significantwhen at least three of seven criteria are met. The bright-line three: more than 10 million holders; more than €5 billion issued or in reserve; more than 2.5 million transactions worth €500 million a day. Cross that line and supervision of the issuer moves from the national authority to the EBAThe European Banking Authority — ESMA's banking-side sibling, responsible for MiCA's stablecoin rulebook. It drafts; the Commission adopts., with higher own-funds and liquidity duties attached.
Check yourself
Caravel's issuer (euro + gold, from the gallery) projects a €40m reserve. What is its minimum own-funds line?
EMTs: the e-money title
Title IV is shorter because it borrows a rulebook that already existed. An e-money token may be offered only by its issuer, and its issuer must be a credit institution or an authorised e-money institution — MiCA builds no third licence for this. The token itself is deemed electronic money: issued at par on receipt of funds, redeemable at any time, at par, in funds. No interest may make holding it more attractive than holding money.
The paperwork is a notification, not an approval: the white paperThe disclosure document MiCA requires before most crypto-assets are offered to the public or admitted to trading — contents prescribed, liability attached, notified to the regulator. is notified to the authority and published before the offer. And one deeming provision catches the unwary: an e-money token referencing a member state’s currency is deemed offered to the public in the Union — a euro token cannot argue it was never really offered here.
Check yourself
A fintech with no licence of any kind has built a flawless euro token — full reserve, instant redemption, audited. May it launch?
What the market actually did with the two titles
The register layer tells the story better than any commentary: at the 24 August 2026 snapshots, 43 e-money-token white-paper records from 23 issuers stood against zero authorised ARTAsset-referenced token — a crypto-asset claiming to hold a stable value by referencing anything other than exactly one official currency: a basket, gold, another asset. MiCA checks e-money tokens first; ART is the stablecoin residual (Title III). issuers. The bespoke title — the one with the novel authorisation, the reserve rules, the EBAThe European Banking Authority — ESMA's banking-side sibling, responsible for MiCA's stablecoin rulebook. It drafts; the Commission adopts. waiting at the thresholds — is empty; the borrowed e-money rulebook is where the entire live stablecoinA token designed to track a currency, run by an issuer who can typically freeze balances — e.g. USDT or USDC. market went. Plan against the regime that exists, not the one on the Regulation’s org chart.
And read the issuer roll for what it is by construction: because only credit institutions and e-money institutions may issue EMTsE-money token — a crypto-asset claiming a stable value by referencing exactly one official currency, such as the euro. Only credit institutions and e-money institutions may issue them (MiCA Title IV). at all, every name on that register already holds a banking or e-money licence — the list is definitionally a roll of dual-regime institutions, with names like CACEIS BANK SA sitting alongside the crypto-native e-money houses.
The dual-licence institution: one brand, two doors
What does it look like when a group holds both a banking licence and MiCA permissions? The held records carry a worked example. Revolut Bank UAB has held a banking licence from the Bank of Lithuania since 13 December 2021 — the authority’s own register entry, captured for this course. And the ESMAThe European Securities and Markets Authority — the EU-level supervisor that drafts most of MiCA's detailed rules and keeps its registers. It drafts; the Commission adopts.CASPCrypto-asset service provider — a firm authorised under MiCA to provide one or more of the ten listed crypto-asset services in the EU. One home-state authorisation covers the whole Union. register’s snapshot shows Revolut Digital Assets (Europe) Ltd authorised as a CASP by Cyprus’s CySEC (notification dated 20 October 2025), for six of the ten services, passported into 29 states.
Two entities, two doors, one brand — and the lesson cuts in both directions. For the group, the doors are genuinely different: a credit institution can notify its way into crypto-asset services and may issue an e-money token on its banking licence, while a standalone entity takes the full CASPCrypto-asset service provider — a firm authorised under MiCA to provide one or more of the ten listed crypto-asset services in the EU. One home-state authorisation covers the whole Union. authorisation route — so a dual-regime group can choose, entity by entity, which door each business walks through. For everyone else, the lesson is entity precision: the MiCA permissions live in the named Cyprus company, the banking licence in the Lithuanian one, and which entity is on your contract decides which regime — and which protections — you actually have.
And then the group’s stablecoinA token designed to track a currency, run by an issuer who can typically freeze balances — e.g. USDT or USDC. arrived through a door this section has not taught yet — the third one. In its announcement of 8 August 2026, the group launched a euro token under its own brand, EURR, and named the structure in its own disclaimer: the token is an e-money token issued by Bridge Building S.A. — a Luxembourg EMI, and a different group entirely — and offered byRevolut Digital Assets (Europe) Ltd, the Cyprus CASPCrypto-asset service provider — a firm authorised under MiCA to provide one or more of the ten listed crypto-asset services in the EU. One home-state authorisation covers the whole Union.. The registers already carried both halves: Bridge Building S.A. sits on the EMTE-money token — a crypto-asset claiming a stable value by referencing exactly one official currency, such as the euro. Only credit institutions and e-money institutions may issue them (MiCA Title IV). white-paper roll (notified via Luxembourg’s CSSF on 23 July 2026, its white-paper link naming EURR, with token identifiers on eight networks), and the offeror sits on the CASP roll. That third door is in Article 48 itself: with the issuer’s written consent, persons other than the issuer may offer an EMT to the public. Brand, offeror and issuer are three different companies in three member states — and only the registers, not the brand, tell you which is which.
Source: the group’s own announcement, 8 August 2026 (captured 27 August 2026), read against the register snapshots of 24 August 2026 cited below.
Check yourself
A group holds a banking licence through one entity and a CASPCrypto-asset service provider — a firm authorised under MiCA to provide one or more of the ten listed crypto-asset services in the EU. One home-state authorisation covers the whole Union. authorisation through another. Its bank announces it will issue a euro token. Which door does that walk through — and what would you expect to see on the registers?
What issuing costs, day to day: the issuer’s operating stack
Everything above answered who may stand behind a token; these five modules are what standing behind one costs, every day after authorisation. They read exactly like Section 6’s CASPCrypto-asset service provider — a firm authorised under MiCA to provide one or more of the ten listed crypto-asset services in the EU. One home-state authorisation covers the whole Union. modules — the question, the desk work, the boardroom meaning, the citations at their stages — because they are the same discipline pointed at the other side of the market. EMTE-money token — a crypto-asset claiming a stable value by referencing exactly one official currency, such as the euro. Only credit institutions and e-money institutions may issue them (MiCA Title IV). issuers: read the bad-days module’s note first; Title III’s recovery-and-redemption chapter reaches you too.
How much capital stands behind the promise — and when must it rise?
The own-funds line is the first number every stablecoinA token designed to track a currency, run by an issuer who can typically freeze balances — e.g. USDT or USDC. plan must survive, and it moves twice: with the reserve, and with the supervisor's risk read.
At the desk
Hold, at all times, the highest of three floors: EUR 350,000; 2% of the average reserve of assetsThe pool an asset-referenced token issuer must hold so the token can always be redeemed. Its composition and liquidity are regulated separately from the issuer's own money.; a quarter of last year's fixed overheads.
Track the average reserve daily — the 2% floor is computed on end-of-day figures over the preceding six months, summed across every ARTAsset-referenced token — a crypto-asset claiming to hold a stable value by referencing anything other than exactly one official currency: a basket, gold, another asset. MiCA checks e-money tokens first; ART is the stablecoin residual (Title III). you issue.
Build the stress-testing programme the adopted RTSRegulatory technical standard — detail an EU authority drafts and the European Commission adopts as a delegated regulation. Until adoption, scrutiny and publication it is a draft, not law. requires, and expect the authority to read it: its results feed the uplift decision.
Plan for the uplift: the home authority can require up to 20% more own fundsThe firm's own capital — the money that absorbs losses before anyone else's. MiCA sets floors and can require more. where risk management, reserve quality and volatility, or the rights granted to holders indicate higher risk.
In the boardroom
Capital scales with the promise, not with revenue: growing the token grows the reserve, and 2% of the reserve is the floor that usually binds. Price growth plans against it.
The 20% uplift is the supervisor's lever on quality: weak controls or a volatile reserve raise the capital line without any rule changing.
So what— Put the three floors and the uplift trigger on one page with live numbers, refreshed monthly. The day the binding floor changes from EUR 350,000 to 2% of reserve is the day the business model is real.
What must the reserve hold — and how fast must it turn to cash?
The reserve is the promise made physical. One layer of its rules is adopted and binds; the sharpest layer is still a draft — and the difference is exactly what the moving edge teaches.
At the desk
Keep a reserve segregated from your own assets, composed and managed so the tokens are backed in substance at all times.
Write the liquidity management policy the adopted RTSRegulatory technical standard — detail an EU authority drafts and the European Commission adopts as a delegated regulation. Until adoption, scrutiny and publication it is a draft, not law. requires: robust strategies and processes to identify, measure and manage liquidity risk, keeping reserve levels adequate.
Where you issue more than one token, set out the policy per token — the RTS expects each reserve's management to be legible on its own.
Treat the pending liquidity ladder — minimum bank deposits per currency, concentration limits, the over-collateralisationHolding reserve assets worth more than the tokens they back — a buffer against falls in the reserve's value, sized by rule rather than by comfort. add-on — as a draft: nothing to comply with tonight, everything to plan against.
In the boardroom
Liquidity rules decide who your banks are: deposit minimums and concentration limits, if adopted as drafted, turn reserve management into a bank-relationship strategy. The consultationThe stage where a draft law or rule is published for comment before it is adopted — the one moment arguments can still shape the text. National systems name it differently; Swiss practice says Vernehmlassung for statutes, Anhörung for regulators' rules. record on that fight is on the moving-edge page.
So what— Split the reserve file into two tabs — 'binds now' (Article 36 + the adopted policy RTS) and 'still a draft' (the ladder) — and date both. Most reserve mistakes are stage mistakes.
What happens when an issuer wobbles — before anyone fails?
Two plans, written in peacetime: one for recovering, one for winding the promise down in an orderly way. Both are judged long before they are needed.
Who this speaks toEMT issuers too: Title III's recovery-and-redemption chapter applies to them mutatis mutandis through Article 55 — though the reserve-of-assets sections do not reach credit institutions issuing EMTs.
At the desk
Structure the recovery plan as the guidelinesA supervisory authority's published position on how rules should be applied. EU guidelines bind authorities on a comply-or-explain basis — they are not themselves the law. do: a summary, then governance information, recovery options, and a communication-and-disclosure plan.
Choose indicators that are both quantitative and qualitative, calibrated to your own risk profile — and include the one indicator required of every issuer: de-peggingA stabilising token losing its promised link to the value it references. Every ART and EMT issuer's recovery plan must carry an indicator tracking this risk. risk.
Vary the scenarios: the guidelines expect a set diverse enough to cover the ways your specific token could come under stress.
Know the redemption plan's trigger precisely: it is implemented on the competent authorityThe national regulator a member state designates to supervise under an EU regime — the licensing and supervision counterpart. Often shortened to NCA.'s decision that the issuer is 'unable or likely to be unable to fulfil its obligations' — not on your own assessment.
In the boardroom
These plans are pre-crisis filings, reviewed in calm weather. A thin recovery plan reads as a governance finding today, not a contingency for later.
The redemption trigger sits with the supervisor. Once that decision is made, the plan you wrote years earlier is the script — which is the argument for writing it as if it will run.
So what— Test the de-pegging indicator this quarter: who sees it, at what threshold, and what meeting does it convene? An indicator nobody is wired to act on is a paragraph, not a control.
Who answers for the token, day to day?
The governance guidelinesA supervisory authority's published position on how rules should be applied. EU guidelines bind authorities on a comply-or-explain basis — they are not themselves the law. write the minimum content of how an issuer is actually run — and the suitability standard for the people running it is the same joint standard CASPCrypto-asset service provider — a firm authorised under MiCA to provide one or more of the ten listed crypto-asset services in the EU. One home-state authorisation covers the whole Union. boards face.
At the desk
Cover the guidelines' three titles in your framework: the management bodyThe board — the people who direct the firm and answer for it. MiCA assesses them one by one and as a collective.'s role and composition, its management and supervisory functions, and the governance framework itself.
Run risk across all three lines of defence — the business managing its risks, the control functions checking, audit assuring — with the management body owning the strategy.
Apply proportionality honestly: the guidelines scale with nature, scale and complexity, but proportionality adjusts depth, never removes a topic.
In the boardroom
The suitability bar for an issuer's board is the joint EBAThe European Banking Authority — ESMA's banking-side sibling, responsible for MiCA's stablecoin rulebook. It drafts; the Commission adopts./ESMAThe European Securities and Markets Authority — the EU-level supervisor that drafts most of MiCA's detailed rules and keeps its registers. It drafts; the Commission adopts. standard — the same one Malta's questionnaire machinery enforces on CASPs. Nobody at this table is exempt from the fit-and-proper file.
So what— Map your current governance pack against the guidelines' three titles and mark every gap with an owner and a date. The map is the artefact an examiner asks for first.
When does your supervisor change to the EBA?
Significance is measured, not chosen: cross the thresholds and supervision itself moves — with heavier duties and the EBAThe European Banking Authority — ESMA's banking-side sibling, responsible for MiCA's stablecoin rulebook. It drafts; the Commission adopts.'s own fee schedule attached.
At the desk
Track the seven criteria continuously, with the three bright lines on a dashboard: 10 million holders; EUR 5 billion issued, capitalised or reserved; 2.5 million transactions worth EUR 500 million a day.
Report the data honestly and on time — classification runs on the information periods the Regulation defines, not on press coverage.
On classification, expect the mechanics of the EBA's transfer decision: supervision, colleges and reporting lines change owner.
In the boardroom
Significance is a cost event as well as a supervisory one: higher own-funds and liquidity duties, plus the EBA's supervision fees. Model the thresholds into growth scenarios before marketing does.
So what— Add the three bright lines to the same monthly page as the own-funds floors. The issuer stack's numbers belong together — and the board should see the distance to each line, not just today's value.
So what— So what — before any stablecoinA token designed to track a currency, run by an issuer who can typically freeze balances — e.g. USDT or USDC. conversation goes past a whiteboard, answer the issuer question in writing: which licence would this need, who holds it, and what do the own-funds and redemption lines cost at the projected size? The definitions chose your counterparties in Section 2; this section prices them.
Regulation (EU) 2023/1114 (MiCA) · applicable — this binds · verified 2026-08-26 · Read the text ↗
Commission Delegated Regulation (EU) 2025/1125 · applicable — this binds · verified 2026-08-26 · Read the text ↗
Commission Delegated Regulation (EU) 2024/1506 · applicable — this binds · verified 2026-08-26 · Read the text ↗
EBA Guidelines on recovery plans under Articles 46 and 55 of MiCA (EBA/GL/2024/07) · issued guidelines — comply-or-explain, binding authorities rather than firms · verified 2026-08-26 · Read the text ↗
EBA Guidelines on redemption plans under Articles 47 and 55 of MiCA (EBA/GL/2024/13) · issued guidelines — comply-or-explain, binding authorities rather than firms · verified 2026-08-26 · Read the text ↗
ESMA register of authorised CASPs - CSV snapshot, 24 Aug 2026 · issued guidelines — comply-or-explain, binding authorities rather than firms · verified 2026-08-26 · Read the text ↗
Bank of Lithuania register entry - Revolut Bank UAB, banking licence valid from 13 Dec 2021 (captured 27 Aug 2026) · issued guidelines — comply-or-explain, binding authorities rather than firms · verified 2026-08-27 · Read the text ↗
ESMA register of EMT white papers - CSV snapshot, 24 Aug 2026 · issued guidelines — comply-or-explain, binding authorities rather than firms · verified 2026-08-26 · Read the text ↗
ESMA register of ART issuers - CSV snapshot, 24 Aug 2026 · issued guidelines — comply-or-explain, binding authorities rather than firms · verified 2026-08-26 · Read the text ↗
As at — instrument lifecycle stages verified 2026-08-26 to 2026-08-27, per instrument (each citation above shows its own date); register figures are from the dated snapshots of 24 August 2026. Issuer restrictions, own-funds floors, redemption rights and significance thresholds re-read in the held Regulation text; market figures from the dated register snapshots.