Stablecoin Issuers Under MiCA (ARTs and EMTs)
Stablecoins sit at the centre of much of MiCA’s design, reflecting EU regulators’ concerns about the systemic and consumer-protection risks these tokens can pose if poorly managed. Issuers of asset-referenced tokens (ARTs) and e-money tokens (EMTs) face some of the most detailed requirements in the entire regulation.
Authorisation Requirements
Issuing an ART generally requires authorisation as a legal person established in the EU, meeting governance, capital and operational standards broadly comparable to those applied to CASPs, but with additional obligations specific to reserve management. EMT issuance is generally reserved for credit institutions and electronic money institutions.
Reserve of Assets
ART issuers must maintain a reserve of assets that matches the claims of token holders, invested in low-risk, highly liquid instruments, and must have clear policies on custody and investment of that reserve. The reserve must be legally segregated from the issuer’s own assets and, in most cases, held with independent custodians.
Redemption Rights
Token holders must generally have a right to redeem their tokens against the issuer at any time, at the value of the assets referenced, and issuers must have clear, disclosed redemption policies and processes to ensure this right can be exercised in practice, including during periods of market stress.
Significant Tokens
ARTs and EMTs that reach certain size or usage thresholds are classified as “significant,” triggering additional requirements and direct oversight involvement from the European Banking Authority alongside the national competent authority, reflecting their greater potential systemic footprint.
Considerations for Prospective Issuers
Businesses considering launching a stablecoin from Cyprus should engage with reserve management, custody and redemption mechanics at the design stage, since retrofitting these features into an existing token structure is far more difficult than building them in from the outset.
Enalian advises crypto-asset businesses, investment firms and payment institutions on MiCA authorisation, notification and ongoing compliance in Cyprus. If you are planning a CASP application or reviewing your regulatory status, our team can guide you through the process. Get in touch with our team to discuss your specific circumstances.
This article is provided for general informational purposes only and does not constitute legal, tax or regulatory advice. Regulatory requirements are subject to change; readers should seek specific advice on their circumstances before taking action.
