Steps for USDC issuers following Circle’s MiCA authorization

Post-deadline requirements for e-money tokens

Circle Mint France SAS holds an Electronic Money Institution license from the Autorite de Controle Prudentiel et de Resolution to issue USDC and EURC in the EU. This status follows the July 1, 2026, transitional deadline for the Markets in Crypto-Assets regulation. As of March 12, 2026, the EU market contained 19 authorized e-money token issuers across 11 countries. These issuers manage 29 different e-money tokens, including entities like Quantoz Payments and Bridge Building S.A. To operate, issuers must obtain authorization as an electronic money institution or a credit institution. These tokens must maintain 1:1 backing with the referenced currency. While asset-referenced tokens require authorization from a national competent authority and a white paper approved by that authority, e-money tokens follow similar paths but remain pegged to a single fiat currency. Most global stablecoins remain outside the regulatory perimeter. The European Banking Authority and National Competent Authorities oversee these entities to maintain financial stability and consumer protection across the entire European Union.

Documentation and reserve management

Issuers must publish a white paper and notify the relevant National Competent Authority before offering tokens to the public. This document contains the specific characteristics of the crypto-asset and the rights of the holders. You should verify these specific details against your regulatory filing to ensure no omissions occur. Issuers also manage governance and internal controls to satisfy European Banking Authority expectations. This involves implementing risk management systems and AML procedures. Firms must also publish the composition of reserves and audit results at regular intervals. Senior management must maintain competence and good repute to hold the license. Regulatory authorities monitor these activities to ensure market integrity.

The white paper must disclose the distributed ledger technology used, the consensus mechanism, and the incentive mechanisms. It also requires details on the rights of holders, such as the right of redemption at par value and the conditions for modifying rights or obligations. The white paper must also include information on the financial condition of the issuer over the past three years, the legal entity identifier, and details regarding the compensation schemes available to holders. Crypto-asset service providers face tiered minimum capital thresholds. Lower-risk services like order execution or advice require €50,000. Exchange or custody services require €125,000, while operating a crypto trading platform requires €150,000. Issuers must also maintain plans for orderly wind-down and segregation of customer assets from company funds.

Market access and competitive pressure

The requirement to hold 60 percent of e-money token reserves in European bank deposits creates friction for some global issuers. Tether chose not to apply for e-money token authorization because it avoids restructuring its reserve model to meet this bar. This decision prevents USDT from being listed on licensed European exchanges. Circle secured its compliance through its French entity, which provides access to the entire EU via passporting rights. France authorized 26 percent of all e-money token issuers, including five different licenses. Compliance teams must establish segregated reserve accounts containing liquid, low-risk assets such as cash or short-term government debt to satisfy the mandatory 100 percent reserve backing requirement that the European Union regulation dictates for all issuers. In the European market, issuers like Societe Generale-FORGE and Quantoz Payments have already secured authorization. These companies manage assets like EURCV and USDQ respectively. This regulatory move creates a bifurcated market where compliant issuers gain access to licensed platforms while others face exclusion. The distinction between being an authorized issuer and a service provider remains a primary hurdle for new entrants seeking market share. While Circle moves into the gap, what happens to the liquidity once held by non-compliant tokens?