Asset-referenced tokens need ESMA approval. E-money tokens require EMI licensing. The distinction determines your compliance path.

The Markets in Crypto-Assets regulation treats stablecoins differently depending on their structure. E-money tokens (EMTs) pegged to a single fiat currency face one set of rules. Asset-referenced tokens (ARTs) backed by baskets of assets face another. The distinction isn't academic: it determines which regulator you answer to and what capital you need.

The two stablecoin categories

MiCA's stablecoin provisions create a clear split:

E-money tokens (EMTs): Stablecoins pegged to a single official currency, like USDC or EURC. These are treated as electronic money under existing EU law. Issuers must be authorized as credit institutions or electronic money institutions (EMIs).

Asset-referenced tokens (ARTs): Stablecoins backed by multiple assets, currencies, or commodities. Think algorithmic stablecoins or basket-pegged tokens. These require specific MiCA authorization from national regulators and, for "significant" ARTs, ESMA oversight.

The practical implication: if your stablecoin is 1:1 with EUR or USD, you need an EMI license. If it's backed by gold, a basket of currencies, or algorithmic mechanisms, you need ART authorization.

EMT requirements

E-money token issuers under MiCA must:

Hold EMI or credit institution authorization in an EU member state
Maintain reserves in segregated accounts equal to 100% of outstanding tokens
Invest reserves only in secure, low-risk assets (government bonds, overnight deposits)
Provide redemption at par value on demand
Publish a white paper with specified disclosures

Circle's EURC and USDC have navigated this path. Circle obtained a French EMI license in 2024, making it the first major stablecoin issuer fully compliant in the EU. The reserves sit in European banks, segregated and audited.

Tether took a different approach. Rather than pursue EU authorization, Tether has indicated it will not offer USDT to EU residents after full MiCA enforcement. Exchanges like Coinbase EU have already delisted USDT in anticipation.

ART requirements

Asset-referenced tokens face stricter rules:

Authorization from national competent authority (not just EMI registration)
Reserve assets must cover 100% of token value plus a capital buffer
For "significant" ARTs (over EUR 5 billion market cap or 10 million holders), ESMA becomes the direct supervisor
Enhanced governance requirements including risk management frameworks
Potential restrictions on issuance volume if the token threatens financial stability

No major ART has yet received authorization under MiCA. The market has consolidated around EMT-style single-currency stablecoins, which face a clearer regulatory path.

What this means for crypto businesses

Exchanges and payment providers need to assess which stablecoins they can legally support in the EU post-July 2026:

Compliant options: USDC, EURC (Circle), and any stablecoin issued by an EU-authorized EMI or credit institution.

Non-compliant: USDT (Tether), algorithmic stablecoins without authorization, stablecoins issued by non-EU entities without passporting.

The practical effect is a narrowing of stablecoin options in EU markets. Dollar-denominated stablecoins remain available (USDC), but the market leader (USDT) is exiting.

For businesses building on stablecoins, the safest approach is to integrate only with MiCA-authorized tokens and build compliance infrastructure that can verify token status against the ESMA registry once it's populated.