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Europe wrote the crypto rulebook first.

MiCA is the first comprehensive crypto regime in a major economy. For payments people the action is in stablecoins: how they are classified, how they must be backed, and why a dollar stablecoin can be throttled the moment it starts being used to buy things in euros.

MiCA EMT ART CASP Article 23

What MiCA is

Markets in Crypto-Assets (Regulation (EU) 2023/1114, “MiCA”) is the EU’s comprehensive framework for crypto-assets not already covered by existing financial law. It regulates two things that matter to payments: stablecoin issuance and the authorisation of crypto-asset service providers (CASPs) — exchanges, custodians, brokers.

MiCA’s significance is that it is genuinely first. It defines token categories, forces reserves and redemption rights, and gives a single passport across the EU. Like most European rules, it is being copied and adapted elsewhere — which is why it matters even outside Europe.

EMT vs ART

MiCA splits stablecoins into two regulated categories, plus a residual “other crypto-asset” bucket. The distinction drives everything that follows.

E-money token (EMT)Asset-referenced token (ART)
ReferencesA single official currency (e.g. 1 USDC = 1 USD)A basket / other assets, commodities, or multiple currencies
Issuer must beAn authorised credit institution or e-money institutionAn authorised ART issuer (or credit institution)
RedemptionAt par, any time, in the referenced currencyAt market value of the reserve assets
Interest to holdersProhibitedProhibited

Most familiar fiat stablecoins (USDC, EURC, USDT) are EMTs in MiCA terms. Reserves must be 1:1, segregated, and audited, held largely in high-quality liquid assets.

Article 23 — throttling non-euro payment stablecoins

MiCA’s most contested provision targets the use of non-EU-currency stablecoins as a means of payment. The intent, stated openly by the ECB during negotiation, is to stop a dollar stablecoin from becoming a parallel payment currency inside the euro area.

The cap

When a non-euro EMT is used as a means of exchange within the EU, issuance/activity is capped at 1 million transactions per day or EUR 200 million per day in value, whichever is hit first.

Stop-issuance trigger

Cross the cap and the issuer must stop issuing that token until activity falls back below the threshold.

Means of payment only

The cap targets payment use — buying goods and services. Using a dollar stablecoin to trade crypto or in DeFi is explicitly not the target.

Euro stablecoins unaffected

A euro-denominated EMT (e.g. a compliant EURC) faces no such payment cap — by design, this favours euro stablecoins for everyday payment use.

Authorisation and the timeline

MiCA phased in: the stablecoin (EMT/ART) provisions applied from 30 June 2024, and the CASP / general provisions from 30 December 2024. Existing CASPs operating under national regimes had a transitional (“grandfathering”) window; the longest such window runs to 1 July 2026, after which a full MiCA CASP authorisation is required to keep operating.

The grandfathering door is closing

As of May 2026, the transitional period for CASPs ends 1 July 2026 in member states that took the full 18 months. After that, no authorisation means no lawful service.

EMT transfers may need PSD authorisation too

An EBA opinion (12 February 2026) flagged that moving EMTs can constitute a payment service — potentially requiring separate PSD2 (soon PSR) authorisation on top of MiCA. Do not assume one licence covers both.

What it means for you

If you issue or plan to issue a stablecoin for EU payment use: denominate in euro unless you have a deliberate reason not to. A non-euro EMT used for payments lives under the Article 23 cap, which makes it structurally unsuitable as a high-volume European payment instrument.

If you are a CASP: the 1 July 2026 cliff is the immediate risk. If your authorisation is not granted (not just applied for) by your member state’s deadline, you cannot lawfully serve EU clients. Treat this as a hard go-live, not an aspiration.

Cost of being wrong: assuming MiCA is one licence. The MiCA + PSD overlap on EMT transfers, plus separate AML registration, means a payment-oriented stablecoin business can need multiple authorisations. Map them before you build the product, not after.

Where this connects

Primary sources