To check whether a stablecoin is authorized for use in the EU, identify its legal issuer and MiCA category, then verify the issuer and token documents in ESMA’s public MiCA register. The checks differ for asset-referenced tokens (ARTs) and e-money tokens (EMTs). A peg, reserve claim, or exchange listing is not proof of issuer authorization—and authorization does not guarantee that the token will maintain its value.
What to identify before searching
Start with the token’s current documentation, not just its brand name or ticker. Record its exact name, ticker, blockchain or network if relevant, and the legal entity identified as its issuer. Then check whether the documentation classifies the token under MiCA as an ART or an EMT. MiCA defines these categories by what value the token purports to maintain, not by marketing language. The definitions appear in Article 3.
- ART: purports to maintain a stable value by referencing another value or right, or a combination of them.
- EMT: purports to maintain a stable value by referencing the value of one official currency.
A token’s name or claimed peg alone does not establish its legal category. If the issuer’s current documentation and the register do not clearly match, do not assume that a similarly named token or ticker is the same asset.
ART and EMT issuer checks differ
| Check | Asset-referenced token (ART) | E-money token (EMT) |
|---|---|---|
| What value it references | Another value or right, or a combination | One official currency |
| General issuer route | Under Article 16, the issuer generally must be an EU-established legal person or other undertaking authorised by its home Member State competent authority, or a credit institution meeting MiCA’s requirements. | Under Article 48, the issuer generally must be authorised as a credit institution or an electronic money institution. |
| White paper | Check the token’s current white paper and any modified white paper recorded in the register. | Article 48 requires notification and publication of a crypto-asset white paper, subject to exemptions; check the relevant documentation and register record. |
| Qualifications to check | Article 16 contains exceptions, including conditions concerning the 12-month average outstanding value and offers addressed solely to qualified investors. Whether an exception applies depends on the legal facts. | Article 48 includes exemptions. Do not infer that an exemption applies from a token’s peg, exchange listing, or marketing materials. |
The governing provisions are MiCA Articles 16 and 48. Their general rules are not a substitute for checking the particular issuer’s legal status and any applicable exception.
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How to check the ESMA MiCA register
- Open ESMA’s public MiCA register. ESMA maintains a public register under Article 109 of MiCA and updates it regularly.
- Search by the issuer’s legal name. Use the entity named in the token’s current documentation. Search the token name as well, but do not rely on a ticker alone.
- Match the record to the asset. Compare the legal entity, token name, and identifying details with the issuer’s documents. A record for a different company or similarly named token does not establish that the asset you are checking is covered.
- Inspect the authorisation details and white paper records. Check the current white paper and any modified version, and confirm that the authorization information fits the token’s ART or EMT category.
- Check dates, status, and recorded measures. Look for withdrawals or other relevant supervisory measures, and distinguish current status from historical entries. Article 109 provides for withdrawals and specified notified supervisory measures to remain published for five years, so an old listing alone is not evidence of current permission.
- Apply the category-specific test. For an ART, check the Article 16 route and any relevant qualification or transition. For an EMT, check the issuer’s credit-institution or electronic-money-institution status and the Article 48 white-paper requirements, while accounting for any stated exemption.
The register is a verification starting point, not a reason to skip matching the record to the issuer’s current legal documents. If the relevant entry is missing, unclear, or appears inconsistent with those documents, avoid treating the token as verified and consult the competent authority or qualified legal advice for a definitive determination.
Account for the EU application date and ART transitions
In an answer published by ESMA on January 17, 2025, the European Commission stated that, since June 30, 2024, an ART or EMT offered to the public or admitted to trading in the Union must have an EU-authorised issuer, subject to ART transitional provisions. The answer also addresses offers made by persons other than the issuer. MiCA Articles 143(4) and 143(5) contain the ART transitional provisions referenced in that answer.
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This summary does not resolve every exemption or transition for every token or historical period. When checking a particular asset, use the current legal text and the dated register record rather than applying the general date statement without context.
Issuer authorization is not platform authorization
A token issuer and the exchange, custodian, or other intermediary you use are separate entities with separate regulatory checks. MiCA Article 59 separately regulates the provision of crypto-asset services. If you want to know whether a platform or custodian is authorised, check that provider’s own status; an authorised issuer does not establish that the service provider is authorised.
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What authorization does—and does not—tell you
Issuer authorization is a regulatory-status check, not a promise that a stablecoin will hold its peg or that you cannot lose money. The joint European Supervisory Authorities’ 2025 consumer factsheet cautions that “stablecoins may not be so stable overtime, especially in stressed market conditions.” Consider peg, redemption, reserve, and counterparty risks separately from the issuer’s authorization status.
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