MiCA Compliance Checker: Is Your Stablecoin EU-Compliant?

What Is MiCA?

The Markets in Crypto-Assets Regulation (MiCA) is the European Union's comprehensive regulatory framework for crypto assets. It establishes uniform rules across all 27 EU member states for the issuance, offering, and trading of crypto assets that are not already covered by existing financial services legislation. MiCA is the first major jurisdiction-wide crypto regulation to reach full enforcement, making it a benchmark that other regions are watching closely.

MiCA divides crypto assets into three categories. E-Money Tokens (EMTs) are tokens that reference a single fiat currency, such as USDC or USDT. Asset-Referenced Tokens (ARTs) reference multiple currencies, commodities, or other assets, similar to a basket-backed stablecoin. Everything else falls under a general "crypto-asset" classification. Each category carries distinct requirements for issuers, including reserve management, redemption rights, governance, and disclosure obligations.

The regulation also establishes licensing requirements for Crypto Asset Service Providers (CASPs): the exchanges, custodians, and brokers that facilitate trading and storage of crypto assets in the EU. Any platform serving EU customers must obtain CASP authorization or operate under an existing financial license.

MiCA Timeline

MiCA followed a multi-year legislative process before reaching full enforcement. Understanding the timeline helps contextualize where the regulation stands today and why some issuers were caught unprepared.

The staggered rollout gave stablecoin issuers a head start. EMT and ART rules went live six months before the broader CASP requirements, giving exchanges time to assess which tokens met the new standards and delist those that did not. This phased approach was intentional: stablecoins were considered a priority because of their systemic importance to crypto markets.

Stablecoin Rules Under MiCA

MiCA imposes specific requirements on stablecoin issuers depending on whether their token qualifies as an EMT or ART. These rules are designed to ensure that stablecoins circulating in the EU are properly backed, transparently managed, and issued by accountable entities.

E-Money Token (EMT) Requirements

EMTs are tokens pegged to a single fiat currency. Under MiCA, EMT issuers must be authorized as an Electronic Money Institution (EMI) or credit institution in an EU member state. Key requirements include:

• Full 1:1 reserve backing in liquid, low-risk assets
• Reserves must be held with EU-regulated custodians
• Holders have the right to redeem at par value at any time
• Issuers must publish a compliant crypto-asset white paper
• Regular reserve reporting to the relevant national competent authority
• Prohibition on paying interest or yield on EMTs

Asset-Referenced Token (ART) Requirements

ARTs reference multiple assets or currencies. Their requirements are stricter because of the additional complexity. ART issuers must obtain specific authorization from their national competent authority and meet additional governance and capital requirements. Significant ARTs (those exceeding certain thresholds in market cap or transaction volume) face even more stringent requirements, including direct supervision by the European Banking Authority (EBA).

CASP Requirements

Crypto Asset Service Providers are the entities that operate exchanges, provide custody, execute orders, or offer portfolio management for crypto assets in the EU. Under MiCA, CASPs must obtain authorization from a national competent authority in at least one EU member state. Once authorized, they can passport their license across all 27 member states.

CASP requirements cover several areas:

• Minimum capital requirements based on the services provided
• Governance and organizational standards, including fit-and-proper requirements for management
• Custody and safeguarding rules for client assets
• Conflict of interest policies and complaints handling procedures
• Market abuse prevention and transaction monitoring
• Mandatory insurance or comparable guarantees for custodial services

For exchanges specifically, MiCA requires that any token listed for trading must comply with the regulation. This means exchanges must verify that stablecoins on their platform are issued by authorized entities. Tokens that do not meet MiCA requirements must be delisted from EU-facing platforms.

Stablecoin Compliance Status

The impact of MiCA is already visible in the stablecoin market. Some issuers prepared early and secured the necessary licenses, while others have been unable or unwilling to meet the requirements. The table below summarizes the current compliance status of major stablecoins under MiCA.

The compliance landscape is evolving. Issuers that have not yet secured authorization may still do so, and regulators are still working through the details of how decentralized protocols fit within the framework. The statuses above reflect the situation as of early 2025 and may change as enforcement actions and licensing decisions progress.

Impact on US-Based Stablecoins

MiCA has had its most visible impact on Tether (USDT), the world's largest stablecoin by market cap. Tether has not obtained EMI authorization in any EU member state, and as a result, major European exchanges have been forced to delist USDT from their EU-facing platforms. Binance, Kraken, and other exchanges with European operations have either removed USDT pairs or restricted access for EU customers.

This shift has created a significant opportunity for Circle, which secured its EMI license in France ahead of the deadline. Both USDC and EURC are fully compliant under MiCA, positioning Circle as the dominant compliant stablecoin issuer in the European market. Trading volumes for USDC on European exchanges have increased as traders migrate away from USDT.

For EU-based businesses and users, MiCA creates clarity but also constraints. Companies that previously relied on USDT for cross-border payments or treasury management must now switch to compliant alternatives. The regulation effectively creates a two-tier stablecoin market: tokens that can be freely traded in the EU and tokens that cannot. This fragmentation may reduce liquidity for some pairs but improves regulatory certainty for institutional participants.

The broader significance of MiCA extends beyond Europe. As the first comprehensive crypto regulatory framework enforced at a continental scale, it is influencing regulatory thinking in other jurisdictions. Issuers and service providers that achieve MiCA compliance may find it easier to meet future requirements in other markets that adopt similar standards.

Frequently Asked Questions

What does MiCA stand for?

MiCA stands for Markets in Crypto-Assets. It is a regulation adopted by the European Union that establishes a unified legal framework for crypto assets across all 27 EU member states. The regulation covers issuance, trading, and service provision for crypto assets that fall outside existing financial instruments legislation.

When did MiCA take effect?

MiCA took effect in two phases. Title III and IV, covering stablecoin rules for EMT and ART issuers, went live on June 30, 2024. The remaining provisions, including CASP licensing requirements, reached full enforcement on December 30, 2024. Issuers and service providers were expected to be compliant by these dates.

Is USDT banned in the EU?

USDT is not explicitly banned, but it cannot be offered on regulated EU exchanges because Tether has not obtained the required EMI authorization. This effectively means EU users cannot buy or trade USDT on compliant platforms. Holding USDT is not illegal, but trading it on EU-regulated exchanges is no longer permitted. Users can still hold existing USDT or trade on non-EU platforms.

What is an EMT under MiCA?

An E-Money Token (EMT) is a crypto asset that references a single official currency, such as the US dollar or the euro. Stablecoins like USDC, USDT, and EURC fall into this category. EMT issuers must be authorized as Electronic Money Institutions or credit institutions in the EU, maintain full 1:1 reserve backing, and grant holders the right to redeem at par value at any time.

What is an ART under MiCA?

An Asset-Referenced Token (ART) is a crypto asset that references multiple currencies, commodities, or other assets. Unlike EMTs, which track a single fiat currency, ARTs aim to stabilize their value through a basket of references. ARTs face stricter authorization requirements and, if classified as "significant," come under direct supervision by the European Banking Authority.

How does MiCA affect decentralized stablecoins like DAI?

MiCA was primarily designed for centralized issuers and service providers. Decentralized protocols like MakerDAO do not have a legal entity that can apply for authorization in the traditional sense. This creates a regulatory gray area. Some EU regulators may treat DAI as an ART and require compliance from entities that facilitate its trading, while the protocol itself remains outside direct regulatory reach. How this plays out will depend on enforcement decisions over the coming years.

Do I need a CASP license to operate a crypto exchange in the EU?

Yes. Under MiCA, any entity providing crypto asset services to EU customers must obtain CASP authorization from a national competent authority in at least one EU member state. This includes exchanges, custodians, brokers, and portfolio managers. Once authorized in one member state, a CASP can passport its license to operate across all 27 EU countries.

Will MiCA affect stablecoin regulations in other countries?

MiCA is widely expected to influence crypto regulation globally. As the first major jurisdiction-wide framework, it sets precedents that other regions are studying. The United Kingdom, Singapore, and Hong Kong are developing their own frameworks with some similarities to MiCA. Issuers and service providers that achieve MiCA compliance may find it easier to meet requirements in these other jurisdictions as regulatory convergence increases.

This tool is for informational purposes only and does not constitute legal or regulatory advice. MiCA compliance status may change as enforcement evolves. Always consult a qualified legal professional for compliance guidance specific to your situation.