Analysis
MiCA Stablecoins: 25 E-Money Token Issuers, No Asset-Referenced Tokens
ESMA's register lists 50 e-money token white papers and an empty asset-referenced token file. Who issues them, from where, and what the file leaves out.
MiCA's stablecoin rules have applied since 30 June 2024. On 22 Oct 2026, ESMA's register listed 50 e-money token (EMT) white-paper entries from 25 issuers, and 0 asset-referenced token (ART) issuers: the ART file is empty (EMTWP.csv, ARTZZ.csv).
Who Can Issue an E-Money Token
Only credit institutions and electronic money institutions may offer e-money tokens to the public, and they must notify a white paper to their authority (Articles 48 and 51 of MiCA). The register shows 44 entries from e-money institutions and 5 from credit institutions. ESMA warns that white papers in its register “have not been reviewed or approved by any competent authority” (ESMA).
What This Means for Exchange Users
A stablecoin that would qualify as an EMT or an ART, but whose issuer is not authorised in the EU, is a “non-MiCA compliant” token. ESMA asked national authorities to make exchanges comply “as soon as possible and no later than the end of Q1 2025” (ESMA, 17 January 2025):
- Exchanges operating a trading platform were expected to stop making such tokens available for trading.
- Order transmission, order execution and crypto-to-crypto or crypto-to-cash exchange services were also to stop where they amount to an offer to the public.
- Restrictions on existing services were to be completed by the end of January 2025. A “sell only” service could run until the end of Q1 2025 so that EU clients could liquidate or convert their holdings.
Holding such a token is not prohibited. ESMA says “mere custody and transfer of these crypto-assets should remain possible”, but warns that the restrictions “can lead to worse execution conditions for investors maintaining holdings” (ESMA). Whether a token's issuer has notified a white paper can be checked in the issuer list on the stablecoins page.
What the File Does Not Tell You
- The file has no token-name column, only the issuer, a white-paper link and Digital Token Identifiers. We do not add token tickers that the file does not state.
- 3 entries are marked as exempt under Article 48(4) and/or 48(5) of MiCA in the ESMA file.
The issuer list is on the stablecoins page.
Sources
- ESMA EMTWP.csv www.esma.europa.eu
- ESMA ARTZZ.csv www.esma.europa.eu
- Regulation (EU) 2023/1114 eur-lex.europa.eu
- ESMA statement on non-MiCA compliant ARTs and EMTs, 17 Jan 2025 www.esma.europa.eu