MiCA stablecoin licensing now has a scoreboard. Three weeks after the transitional period closed on 1 July 2026, the EU register lists 21 authorised e-money token issuers and not one authorised asset-referenced token issuer. The largest stablecoin in the world is absent: USDT, with more than $180 billion in circulation as of mid-July 2026, cannot lawfully be offered to the public in the EU, and authorised venues have spent eighteen months removing it.
For anyone planning a euro or dollar stablecoin aimed at EU users, we think the licensing question is now settled. The route that works is an e-money institution or credit institution authorisation in a member state, and the issuers actually live in the market went through France and the Netherlands. Waiting for an equivalence regime for offshore issuers is a bet on legislation that does not yet exist and that, on the European Commission's own timetable, cannot bite before mid-2027.
Why is Tether not MiCA compliant?
Tether chose not to apply. MiCA requires e-money token issuers to hold an EU authorisation, and issuers of significant tokens must keep at least 60 per cent of reserve funds on deposit with EU credit institutions. Tether's management has said repeatedly since 2024 that it will not accept that concentration requirement. The consequence arrived on schedule: EU-authorised exchanges began removing USDT pairs in late 2024, and ESMA's statement of 17 April 2026 confirmed that all transitional relief ended on 1 July 2026.
The hedge is instructive. Rather than apply, Tether invested in November 2024 in Quantoz Payments, a Dutch issuer supervised by De Nederlandsche Bank whose EURQ and USDQ tokens sit on the register among the 21. Offshore scale, onshore licence: that is the shape of compliant stablecoin distribution in the EU today.
MiCA stablecoin licensing runs through an EMI
Circle proved the route first, on 1 July 2024, when an EMI authorisation from France's ACPR made USDC and EURC compliant, followed in April 2026 by a French AMF CASP authorisation covering custody and transfer services. Register snapshots taken between 18 and 20 July 2026 show just under 300 CASP authorisations against only 21 EMT issuers. That ratio locates the bottleneck: issuing a compliant stablecoin is a bank-grade undertaking with prudential capital, safeguarding and redemption obligations, and most firms that cleared the CASP bar have not attempted it. Founders weighing member states can compare EMI requirements across the EU before committing budget to a filing.
The offshore gap is under review, slowly
On 20 May 2026 the European Commission opened a targeted consultation on the MiCA review, and it names the absence of an equivalence framework for third-country stablecoin issuers as one of the gaps under examination. Responses close on 31 August 2026; a report to the European Parliament and Council follows by 30 June 2027. Equivalence may eventually reopen the EU to offshore issuers, but nothing changes in law before that report, and legislative follow-up would land later still. Launch plans for 2026 and 2027 have to assume the rules as they stand. The wider shake-out, including who converted and who exited, is covered in our State of Crypto Licensing reports.
Sources
- ESMA statement on the end of transitional periods under MiCA, 17 April 2026
- European Commission targeted consultation on the MiCA review, May 2026
- Circle press release on MiCA compliance, 1 July 2024
- Helms Advisory EU CASP licence tracker, snapshot 20 July 2026
This article is informational only and does not constitute legal advice.