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- MiCA (Regulation (EU) 2023/1114) has applied to stablecoin issuers since 30 June 2024 and in full since 30 December 2024.
- ESMA's interim register lists Circle Internet Financial Europe SAS, authorised by France's ACPR as an e-money institution on 1 July 2024, with a USDC white paper.
- ESMA's January 2025 statement told crypto service providers to stop trading non-compliant stablecoins, while saying that mere custody and transfer should remain possible.
Which stablecoins does MiCA cover?
MiCA sorts stablecoins into two kinds by what they track. The definitions are in Article 3(1) of Regulation (EU) 2023/1114:
- E-money token (point 7): "a type of crypto-asset that purports to maintain a stable value by referencing the value of one official currency". ESMA's register lists white papers from Circle's EU entity for USDC, which tracks the US dollar, and EURC, which tracks the euro, among its e-money tokens. How e-money tokens and other stablecoins differ from CBDCs is in stablecoins vs CBDCs vs tokenized deposits.
- Asset-referenced token (point 6): a crypto-asset that is not an e-money token and "purports to maintain a stable value by referencing another value or right or a combination thereof, including one or more official currencies".
Article 48(2) adds that "E-money tokens shall be deemed to be electronic money", which brings them under the EU's existing e-money rules as well. This post is not legal advice. It quotes the texts as published and as read on 15 October 2026; it does not tell you whether any of them applies to what you do.
When did MiCA start to apply to stablecoins?
MiCA's stablecoin rules have applied since 30 June 2024, six months before the rest of the regulation. The dates below come from Article 149 and Article 143 of the regulation, and from the regulators' own pages.
| Date | What happened | Source |
|---|---|---|
| 9 June 2023 | MiCA published in the Official Journal (OJ L 150) | The regulation |
| 30 June 2024 | Titles III and IV apply: the rules for asset-referenced tokens and e-money tokens | Article 149(3) |
| 1 July 2024 | France's ACPR authorises Circle Internet Financial Europe SAS as an e-money institution | ESMA's interim register |
| 30 December 2024 | The rest of MiCA applies, including the rules for crypto-asset service providers | Article 149(2) |
| 17 January 2025 | ESMA asks national authorities to bring service providers into line on non-compliant stablecoins by the end of Q1 2025 | ESMA public statement |
| 10 June 2025 | EBA no-action letter: advises national authorities to treat custody and transfer of e-money tokens by service providers as payment services under PSD2, with that authorisation required only from 2 March 2026 | EBA |
| 1 July 2026 | Latest end of the transition for service providers that operated under national law before 30 December 2024; member states could shorten it | Article 143(3) |
Who does MiCA regulate, issuers or businesses that accept stablecoins?
MiCA regulates issuers, people who offer crypto-assets to the public, and crypto-asset service providers. Article 2(1) says it applies to persons "engaged in the issuance, offer to the public and admission to trading of crypto-assets or that provide services related to crypto-assets in the Union."
For e-money tokens, Article 48(1) says no one may offer one to the public or seek its admission to trading in the EU "unless that person is the issuer of such e-money token" and is "authorised as a credit institution or as an electronic money institution", with a white paper notified and published. Others may offer it only with the issuer's written consent.
The service-provider side turns on definitions in Article 3(1). Two matter for payments. Custody is "the safekeeping or controlling, on behalf of clients, of crypto-assets or of the means of access to such crypto-assets, where applicable in the form of private cryptographic keys". Transfer services are "providing services of transfer, on behalf of a natural or legal person, of crypto-assets from one distributed ledger address or account to another".
None of the definitions quoted here names a business that is paid in stablecoins for its own goods. Whether any of your activities fits one of these definitions is the question to take to a lawyer. The US equivalents, FinCEN's categories and state licences, are covered in do you need a licence to accept crypto payments.
Is USDC allowed under MiCA?
USDC has an authorised EU issuer and a published MiCA white paper, according to ESMA's interim register. The register's e-money token file, which we downloaded on 15 October 2026 from ESMA's MiCA page (marked "Last update: 7 October 2026"), lists Circle Internet Financial Europe SAS, supervised by France's ACPR, authorised as an electronic money institution on 1 July 2024, with a USDC white paper and a EURC white paper. The file has 50 rows from 25 issuing entities in 14 member states.
Circle's MiCA white paper for USDC lists Solana among the networks USDC is issued on, with the token standard "SPL Token". ESMA updates the register files weekly, so check the current file rather than any list in an article, including this one.
What happened to stablecoins without an authorised EU issuer?
ESMA's response to stablecoins without an authorised EU issuer targeted trading and exchange services, not holding them. In its public statement of 17 January 2025, ESMA said national authorities "should ensure compliance by CASPs regarding non-compliant ARTs or EMTs as soon as possible and no later than the end of Q1 2025", and that trading platforms were "expected to stop making" such tokens available for trading. Order and exchange services were to stop too where they amount to an offer to the public, with sell-only services allowed until the end of Q1 2025.
The same statement drew a line around holding and moving them:
For instance, while mere custody and transfer of these crypto-assets should remain possible, EU investors should be clearly informed of the restrictions attached to the provision of crypto-asset services involving non-MiCA compliant ARTs and EMTs, as these can lead to worse execution conditions for investors maintaining holdings in such crypto-assets.
The practical side for a business is conversion. A stablecoin that EU platforms no longer trade can be harder to turn into euros inside the EU, whatever its legal status in your hands. Turning USDC into local currency is covered in turning USDC revenue into local currency.
Does MiCA limit dollar stablecoins used for payments?
MiCA caps how widely a non-euro stablecoin may be used for payments in a currency area, and the duty falls on the issuer. Article 58(3) applies Articles 22, 23 and 24(3) to "e-money tokens denominated in a currency that is not an official currency of a Member State", which includes dollar tokens such as USDC.
Article 23(1) sets the threshold: when the "estimated quarterly average number and average aggregate value of transactions per day associated to its uses as a means of exchange within a single currency area is higher than 1 million transactions and EUR 200 000 000, respectively", the issuer must stop issuing the token and, within 40 working days, submit a plan to bring use back under those figures. Recital 61, written about asset-referenced tokens, says the transactions to estimate are those "associated to payments of debts including in the context of transactions with merchants."
Payments to merchants are therefore part of what the threshold measures, and the duties Article 23 sets are the issuer's.
What does a USDC payment through Fianto involve?
Fianto takes one token on one network: USDC on Solana, mint EPjFWdd5AufqSSqeM2qN1xzybapC8G4wEGGkZwyTDt1v (how to check real USDC on Solana). It does not take EURC or any other stablecoin, and it has no fiat payouts. The customer's wallet signs one transaction that sends USDC straight to the merchant's wallet; Fianto holds no balance and makes no payout, and the merchant pays nothing. The flow is set out on the docs page how money moves and in how to accept USDC on Solana.
See what a recurring USDC payment involves for you and your customer before you talk to counsel.
USDC subscriptionsWhat should an EU business check before accepting stablecoins?
The facts a lawyer will want follow the lines MiCA draws. Bring answers to these:
- Which token, and does ESMA's current register list an authorised issuer and a white paper for it?
- Is every payment for your own goods or services, or do you ever receive tokens to pass on to someone else?
- Does anyone hold the tokens for you between the customer and your wallet, and who controls the keys to your wallet?
- Where will you convert to euros, and does that platform trade the token in the EU?
- Which member states are you and your customers in, and did yours shorten the transition under Article 143(3)?
The US picture, for a business with American customers or an American entity, is in the GENIUS Act explained for merchants. Whether you must identify the people who pay you is covered in do merchants need to KYC crypto payers. Tax is a separate question again.
- Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA), OJ L 150, 9.6.2023: Articles 2, 3, 23, 48, 58, 143, 149 and recital 61
- ESMA: Markets in Crypto-Assets Regulation, interim MiCA register (page last updated 7 October 2026)
- ESMA: interim register, issuers of e-money tokens (EMTWP.csv, downloaded 15 October 2026)
- ESMA public statement ESMA75-223375936-6099 on non-MiCA compliant ARTs and EMTs (17 January 2025)
- EBA: No Action letter on the interplay between PSD2 and MiCA (10 June 2025)
- Circle Internet Financial Europe SAS: MiCA white paper for USDC