Table of Contents
As the end of 2025 approaches, MiCA's provisions covering ARTs and EMTs still apply (since 30 June 2024), and the broader MiCA framework has applied since 30 December 2024.
From an operating standpoint, “2026 stablecoin compliance” is less about waiting for MiCA to start and more about staying aligned with how EU supervisors are applying MiCA to stablecoins today, while preparing for the PSD2–MiCA transition point tied to 1 March 2026 in EBA guidance.
This guide is written for EU-based businesses that use stablecoins for payouts, settlement, treasury, merchant checkout, platform balances, or crypto-enabled product flows.
Key Takeaways
- “MiCA-approved” should be treated as an evidence-backed status covering issuer authorisation and the service chain, not a marketing claim.
- The ECB reported in its November 2025 analysis window that stablecoin market capitalisation exceeds USD 280 billion, representing roughly 8% of the crypto-asset market, with USDT and USDC accounting for the majority.
- ESMA set concrete operational expectations for non-MiCA-compliant ARTs/EMTs in early 2025, including restrictions and limited “sell-only” handling to support liquidation or conversion.
- The EBA advised that certain EMT transfers carried out on behalf of clients and custody/administration of EMTs can constitute PSD2 payment services, with a transition approach up to 1 March 2026.
- The safest posture is to run stablecoin compliance as an end-to-end control system: token eligibility, regulated counterparties, AML/transfer controls, product design decisions, and audit-ready evidence.
Market Context in 2025: Why Stablecoin Compliance Is a Board-Level Topic
EU compliance work happens against a backdrop of rapid stablecoin growth and concentration.
The ECB’s November 2025 Financial Stability Review analysis describes stablecoins’ combined market cap as exceeding USD 280 billion and accounting for roughly 8% of the overall crypto-asset market, with USDT and USDC dominating.
It also notes that euro-denominated stablecoins remain comparatively small, totalling around €395 million within its chart window.
The IMF has also reported very large stablecoin trading volumes in 2024 for the largest USD stablecoins, describing a substantial year-over-year increase.
While this does not automatically translate into retail payment adoption, it does underline why supervisors and banking partners treat stablecoin exposure as a market structure and risk-management topic, not just a product feature.
Core Definitions You Must Get Right: EMT vs ART
Your stablecoin compliance program needs one unambiguous output: a written classification of each stablecoin you touch.
- An "EMT" is a crypto-asset that purports to maintain a stable value by referencing the value of one official currency.
- An "ART" is a crypto-asset that purports to maintain a stable value by referencing another value or right or a combination thereof, including one or more official currencies, and is not an EMT.
The reason this matters is practical:
Obligations, supervisory expectations, and the operational constraints for service providers differ depending on classification.
What “MiCA-Approved Token” Should Mean in 2025 Documentation
In 2025, an EU business should treat “MiCA-approved” as an internal, auditable standard rather than an external label. A conservative definition generally includes:
- Issuer evidence: the issuer is authorised in the EU for the relevant token category.
- Service chain evidence: entities providing crypto-asset services such as custody, execution, exchange, or platform operation are authorised or otherwise lawfully operating under applicable frameworks.
- Distribution and offer controls: your product design does not inadvertently create an “offer to the public” pattern for tokens that are not compliant for EU-facing activity.
Practical tool: ESMA’s Interim MiCA Register
ESMA publishes an interim MiCA register intended to help market participants verify authorisations.
A workable internal process in 2025 is to define a verification cadence aligned to how frequently you ship changes, store dated evidence for issuer and key service partners, and gate new stablecoin integrations on refreshed eligibility checks.
Timeline Anchors to Use in Internal Policies
From a 2025 standpoint, these dates continue to drive implementation and audit conversations:
- 30 June 2024: the MiCA framework for ART and EMT issuers began applying.
- 30 December 2024: the remainder of MiCA began applying.
- Early 2025: ESMA described expectations around restricting non-MiCA-compliant ARTs/EMTs, including a limited “sell-only” handling period to support liquidation or conversion.
- 1 March 2026: EBA guidance references this date as a transition point for PSD2 authorisation or PSP partnership where EMT activities qualify as payment services.
Where EU Businesses Get Caught: Flow Classification
A compliance program that only checks token status often fails once real product flows are mapped.
1. Merchant acceptance and checkout in stablecoins
If customers pay in a stablecoin and you settle to merchants or hold the asset as treasury, controls typically need to cover token eligibility evidence, counterparty risk management for on-ramps and liquidity sources, and appropriate AML/transfer controls based on your role in the transaction chain.
2. Supplier or contractor payouts in stablecoins
A core question is whether transfers are made from your own treasury or initiated on behalf of clients. This distinction becomes important in PSD2–MiCA analysis, because EBA guidance focuses on EMT transfers performed on behalf of clients.
3. Customer wallets and balances, especially custodial
This is where scrutiny can intensify. The EBA has discussed circumstances in which EMT transfer services carried out on behalf of clients and custody/administration of EMTs can be treated as payment services under PSD2.
It also described how a custodial wallet can be regarded as a payment account under certain conditions.
If your stablecoin product includes user balances and third-party “send/receive” functionality, you should assume you will need a documented PSD2 posture.
4. Exchange, routing swaps, execution, or order handling
ESMA has highlighted that certain crypto-asset services can constitute an offer to the public of non-compliant ARTs/EMTs and should cease where that characterization applies.
This means that even if you do not “list” assets, routing swaps or enabling acquisition flows can create exposure.
Non-MiCA-Compliant Stablecoins: The Operational Playbook
If you serve EU users and touch stablecoins that may qualify as ARTs or EMTs, ESMA’s early 2025 statement provides a practical operating direction: restrict availability for trading and manage wind-down or liquidation options in a controlled manner.
For embedded crypto modules and broker-style integrations, this typically requires enforced allowlists, EU user segmentation controls, and well-defined downgrade paths such as sell-only or convert-only handling where applicable.
The 2026 Planning Item From a 2025 Perspective: PSD2–MiCA Overlap
In June 2025, the EBA published an opinion addressing the interplay between PSD2 and MiCA. The operational message for 2026 planning is that certain EMT-related activities can qualify as PSD2 payment services in specific conditions, particularly when they are performed on behalf of clients.
The EBA also advised a transition approach until 1 March 2026.
From a 2025 planning perspective, the correct framing is conditional, not absolute: by 1 March 2026, you need a PSP licence or PSP partnership if your EMT activities fall within PSD2 payment services as described by the EBA.
This avoids guesswork because it ties the requirement to a defined product characterization rather than a blanket assumption.
Audit-Ready Evidence Pack
A strong evidence pack is designed to answer questions quickly and consistently.
Minimum evidence set:
- Token classification memo (EMT vs ART), version-controlled
- Issuer authorisation evidence captured through your eligibility workflow
- Authorisation evidence for key service providers and partners
- A written product and flow classification against the EBA’s PSD2–MiCA criteria for EMT transfers and custody, with an owner and review cadence
- Restriction and communication playbooks for handling tokens that are not eligible for EU-facing activity
Implementation Blueprint for a 2025 Build
First month
- Classify each stablecoin you touch
- Define what “MiCA-approved” means internally and build the eligibility file
- Map every stablecoin flow in your product and identify high-risk patterns such as custody plus third-party transfers
Second month
- Implement allowlists, blocklists, and EU segmentation controls where needed
- Align your restrictions posture with ESMA expectations where applicable
- Complete PSD2 posture work for EMT transfer and custody flows using the EBA’s criteria
Third month
- Build the audit evidence register linking policies to systems, owners, and test cadence
- Run a restriction event simulation and a vendor outage simulation to validate operational readiness
Conclusion
In 2025, the most reliable way to be ready for 2026 is to treat stablecoin compliance as an operating system: verify issuer and partner status, harden product flows that resemble payment services, and maintain an audit-ready evidence trail.
If your EMT functionality involves transfers on behalf of clients or custodial balances with third-party transfers, lock in your PSD2 posture well ahead of 1 March 2026.
Read Next:
- Best Stablecoins for Cross-Border Payments in 2025
- The Role of Stablecoins in Monetary Policy Transmission
- The Neobank Transition Report
FAQs:
1. What qualifies as a “MiCA-approved” stablecoin for EU use?
Operationally, it means the stablecoin falls within EMT or ART categories and the issuer and service chain align with MiCA authorisation expectations, supported by verifiable evidence.
2. What should EU-facing businesses do about non-MiCA-compliant ARTs and EMTs?
ESMA described expectations to restrict availability for trading and to manage transitions in a way that enables orderly liquidation or conversion, with clear customer communications.
3. What is the main 2026 date to plan around?
From a PSD2–MiCA standpoint, EBA guidance points to 1 March 2026 as a transition point for holding PSD2 authorisation or operating with a PSP partner when EMT activities qualify as payment services.
4. Are stablecoins widely used for everyday payments in the euro area?
ECB analysis has described stablecoins as not widely used for real-world transactions in the euro area, while also noting that stablecoins play a major role in crypto trading activity.
Disclaimer:
This content is provided for informational and educational purposes only and does not constitute financial, investment, legal, or tax advice; no material herein should be interpreted as a recommendation, endorsement, or solicitation to buy or sell any financial instrument, and readers should conduct their own independent research or consult a qualified professional.
