If you are costing a euro stablecoin, the MiCA stablecoin authorisation record now separates a proven route from a theoretical one. As at 1 September 2026, 39 e-money tokens (EMTs) had been issued under MiCA and no asset-referenced token (ART) had been authorised under Title III, on figures the European Banking Authority published on 24 September 2026.
That asymmetry should drive the structuring call. EMT issuance runs through a credit institution or an electronic money institution authorisation, and 39 live tokens show that supervisors are willing to see the file through. An ART structure has no completed EU precedent, so any timeline you put in front of a board or an investor rests on assumption rather than observed practice. If your token references a single fiat currency, plan for the EMT route.
Why the ART route is still empty
The EBA's assessment of 24 September 2026 is that MiCA's requirements for ART and EMT issuers are broadly appropriate. It does not attribute the absence of ART authorisations to any single cause, so neither should anyone else. What the EBA does flag is that classification of crypto-assets is a challenge for both industry and supervisors, and that this produces avoidable costs and delays for firms rolling products out. For an applicant, uncertainty over which side of the ART and EMT line a token falls on is a cost that lands before the application is even filed.
What did the EBA ask the Commission to change?
The response names four priorities for the review:
- Third-country multi-issuer schemes, where the EBA wants the framework strengthened against risks it describes as significant to very significant
- Reserve requirements, and specifically the minimum amount of reserves that must be held as deposits
- The scope of, and definitions in, MiCA, to make crypto-asset classification workable
- The reporting framework for issuers and crypto-asset service providers
Reserve requirements are the item with direct balance sheet consequences. The EBA asked the Commission to revisit the minimum deposit share while preserving effective risk management. It did not propose a replacement figure. If you are underwriting EMT economics on today's deposit split, treat that split as capable of moving before you are three years into the licence.
MiCA stablecoin authorisation decisions to take now
The Commission's targeted consultation on the MiCA review closes on 30 September 2026 at 23:59 CEST, after a one-month extension. Responses feed the report the Commission owes under Articles 140 and 142 of MiCA, which may be accompanied by a proposal to amend the regulation.
Three practical points follow. First, if you intend to respond to the consultation, tomorrow is the last day. Second, when choosing between member states, weigh the national authorisation requirements rather than the MiCA overlay, because the overlay is the part now under review: our e-money licensing comparison sets the national positions side by side, and the crypto licensing comparison covers the CASP layer. Third, build the reserve model so that a change in the deposit minimum is a parameter rather than a rebuild.
None of this makes the ART route unusable. It makes it a route you should cost as a first mover rather than as a fast follower. We track what actually changes, quarter by quarter, in our licensing reports.
This article is informational only and is not legal advice.
Sources
- The EBA identifies priorities for the review of MiCA, European Banking Authority, 24 September 2026
- EBA response to the EC targeted consultation on the MiCA review, European Banking Authority, 24 September 2026
- Targeted consultation on the review of MiCA Regulation, European Commission, closing 30 September 2026