MiCA (Regulation (EU) 2023/1114, the Markets in Crypto-Assets Regulation) is the European Union rule that decides who may issue a stablecoin to the public in the EU, what that issuer must hold in reserve, and who may provide services with the token afterwards. It does this by defining two kinds of stablecoin, the e-money token that references one official currency and the asset-referenced token that references anything else, and by requiring a separate authorization for the companies that custody, exchange or transfer them on behalf of clients.
For a payment company the practical questions are three. Whether the stablecoin it wants to use in Europe is issued by an authorized issuer. Whether its own provider is an authorized crypto-asset service provider, or a bank or payment institution allowed to provide the same services. And what the dates are, because MiCA applied in stages and one transition ran into 2026. This post answers those from the regulation's own articles, with the caveat that Lumx describes the rule as an operator and not as counsel.
What MiCA covers and what it leaves to other law
Article 2 of Regulation (EU) 2023/1114 sets the scope: the issuance, the offer to the public and the admission to trading of crypto-assets in the EU, and the provision of crypto-asset services in the EU. It excludes crypto-assets that qualify as financial instruments, deposits, funds other than e-money tokens, securitisation positions and insurance products, which stay under the existing directives.
The rule is not a payments rule. Sending euros through SEPA remains under the payment services directive and the e-money directive. MiCA reaches a payment company when a stablecoin enters the flow, and it reaches the issuer of the stablecoin and the provider handling it, not the client paying a supplier.
Two kinds of stablecoin
Article 3(1) point (7) defines an e-money token as a crypto-asset that purports to maintain a stable value by referencing the value of one official currency. A euro stablecoin, or a dollar stablecoin offered in the EU, is an e-money token. Point (6) defines an asset-referenced token as a crypto-asset that is not an e-money token and that purports to maintain a stable value by referencing another value or right, or a combination, including one or more official currencies. A token pegged to a basket, to gold or to two currencies is an asset-referenced token.
The distinction decides which title of the regulation applies. Title IV covers e-money tokens. Title III covers asset-referenced tokens. Both titles apply from June 30, 2024, under Article 149, six months before the rest of the regulation.
Most of what a payment company calls a stablecoin, in the sense of the stablecoin explainer, is an e-money token under MiCA, so Title IV is the part to read.
Who may issue an e-money token in the EU
Article 48 states that no person shall offer an e-money token to the public in the EU, or seek its admission to trading, unless that person is the issuer and is authorised as a credit institution or as an electronic money institution, and has published a crypto-asset white paper notified under Article 51. E-money tokens are deemed to be electronic money, which pulls the issuer under the e-money directive as well.
Article 49 requires the issuer to issue the token at par value on receipt of funds and to redeem it at par, at any time and at the holder's request. Article 50 prohibits granting interest in relation to an e-money token. Article 54 requires the issuer to deposit at least 30 percent of the funds received in separate accounts at credit institutions, with the remainder invested in secure, low-risk assets denominated in the same official currency as the token.
Article 56 gives the European Banking Authority the power to classify an e-money token as significant, which brings additional requirements and moves part of the supervision to the EBA. For a significant token, the share held as bank deposits rises from 30 to 60 percent under the regulatory technical standards the EBA drafted. The significance criteria are the ones in Article 43 for asset-referenced tokens, applied to e-money tokens.
The consequence for a payment company is a checklist it can run. Who issues the token it plans to use in the EU. Is that issuer authorised as a credit institution or an e-money institution in a member state. Is the white paper notified. If the answer to any of these is unclear, the token is not one that may be offered to the public in the EU under Article 48.
Asset-referenced tokens and the means-of-exchange threshold
Article 16 requires an issuer of an asset-referenced token to be a legal person established in the EU and authorised under Article 21, or a credit institution that has notified its competent authority. Article 36 sets the reserve of assets requirement.
Article 23 is the provision that payment companies notice. Where an asset-referenced token is used as a means of exchange and the estimated quarterly average number and value of transactions per day exceed one million transactions and 200 million euro, the issuer must stop issuing the token and present a plan to bring the figures below the thresholds within 40 working days. The article counts transactions associated with uses as a means of exchange within a single currency area, and the same mechanism applies to e-money tokens denominated in a currency that is not an official currency of a member state, through Article 58(3).
In plain terms, MiCA does not want a non-euro stablecoin to become a mass payment instrument inside the euro area. A payment company building a dollar stablecoin flow for EU customers should read Article 23 and Article 58(3) together before sizing the volume.
Who may handle the token for clients
Article 3(1) point (16) lists the crypto-asset services: custody and administration on behalf of clients, operation of a trading platform, exchange for funds, exchange for other crypto-assets, execution of orders, placing, reception and transmission of orders, advice, portfolio management, and transfer services on behalf of clients.
Article 59 states that only a legal person or other undertaking authorised as a crypto-asset service provider (CASP) under Article 63 may provide those services in the EU, with the exception in Article 60 for regulated financial entities. Under Article 60, a credit institution may provide any crypto-asset service after notifying its competent authority, and an electronic money institution may provide custody and transfer services for the e-money tokens it issues. This is why a bank can operate a stablecoin desk without a separate CASP licence, and why a payment institution cannot.
Article 70 requires a provider holding clients' crypto-assets or funds to make adequate arrangements to safeguard ownership rights and to keep the assets separate from its own. Funds received from clients that are not e-money tokens must be placed with a central bank or a credit institution by the end of the next business day.
The EU version of a VASP (virtual asset service provider, the FATF term) is therefore the crypto-asset service provider, and the VASP explainer compares the EU, Brazilian and US definitions.
The dates and the transition that ended in 2026
Article 149 sets the timetable. The regulation entered into force on the twentieth day after publication in the Official Journal, in June 2023. It applies from December 30, 2024, except for Titles III and IV on asset-referenced tokens and e-money tokens, which apply from June 30, 2024.
Article 143(3) contains the transition for service providers. A provider that offered crypto-asset services under national law before December 30, 2024 could continue until July 1, 2026, or until it obtained or was refused a CASP authorisation, whichever came first, and member states could shorten that period. That window is now closed. A provider operating in the EU today either holds a CASP authorisation, or is a credit institution or an e-money institution acting under Article 60, or is not allowed to provide the service.
When MiCA is not the rule that applies
When no crypto-asset is in the flow. A euro payout through SEPA from a company that only ever holds fiat is a payment service and MiCA does not apply.
When the client is an end user. A business paying a supplier in a stablecoin through an authorised provider is not providing a crypto-asset service, so Article 59 does not reach it. Its counsel should confirm that its own product does not offer custody or exchange to its users.
When the token is a financial instrument. A tokenised security is excluded by Article 2 and sits under the markets in financial instruments directive.
When the counterparty is outside the EU and the service is provided at the client's own initiative. MiCA regulates services provided in the EU, and the reverse solicitation exemption in Article 61 is narrow and policed by the European Securities and Markets Authority, so a payment company should not build a European flow on it.
What this looks like for a client running EUR flows with Lumx
Lumx is stablecoin payments infrastructure for businesses that move money between Latin America and the rest of the world: one API to collect, hold, convert, and pay out in BRL, MXN, COP, USD, EUR, and GBP or in USDC and USDT, over local rails such as PIX, SPEI, PSE, ACH, FEDWIRE, SEPA, and Faster Payments, with SWIFT and on-behalf-of payments and collections (POBO and COBO) in USD, EUR, and GBP, plus named virtual accounts, custodial wallets, and KYB/KYC built in.
A client paying a European supplier from a USDC balance sees a conversion and a SEPA payout in euro; the USDC to EUR corridor page shows that flow, and the EUR to USDC page shows the collection in reverse. The euro leg runs on a regulated payment rail through partners, and the stablecoin leg runs on the entity that provides the virtual asset service for that corridor. The entity per corridor and the countries we serve are on the supported countries page, which is where a compliance lead should check what we say about Europe before assuming anything from this post.
I have stopped answering "is USDC allowed in Europe" with a yes or no. The answer under Article 48 depends on who the issuer is and whether it is authorised as a credit institution or an e-money institution in the EU, and the answer for the provider depends on Article 59 and Article 60, so a yes that skips those two checks is worth nothing to a compliance lead. We now walk a prospect through the issuer question and the provider question separately, in that order, before the corridor is even priced.
KYB (know your business, the verification of a company and its owners) and KYC (know your customer, the verification of an individual) run before the first euro moves, because the safeguarding and record obligations in Title V of the regulation attach to the provider, and the provider needs to know who the client is to carry them.
Methodology and sources
Regulation (EU) 2023/1114 was read on eur-lex.europa.eu on September 24, 2026, and the article numbers above come from the consolidated English text served that day. The transition date in Article 143(3) and the application dates in Article 149 are taken from that text. Lumx's coverage and entity information is stated as it appears on lumx.io on the same date. This post describes what the regulation says; whether a specific company or token falls under a given article is a question for counsel in the member state concerned.
Verified on September 25, 2026. Operational context, not legal, tax, or investment advice. Regulation (EU) 2023/1114 (MiCA) checked against eur-lex.europa.eu on September 24, 2026.
Cover photo: Eldry John Infante on Unsplash.
Is USDC an e-money token under MiCA?
A stablecoin that references one official currency is an e-money token under Article 3(1) point (7) of Regulation (EU) 2023/1114, and a dollar stablecoin fits that definition. Whether a given token may be offered to the public in the EU depends on whether its issuer is authorised as a credit institution or an e-money institution under Article 48 and has notified a white paper.
Does a payment company need a MiCA licence to pay suppliers in stablecoins?
Not for paying its own suppliers through an authorised provider, because it provides no crypto-asset service to third parties. It would need authorisation under Article 59 if it offered custody, exchange or transfer of crypto-assets to its own users.
When did MiCA start to apply?
Titles III and IV, on asset-referenced tokens and e-money tokens, applied from June 30, 2024. The rest of the regulation applied from December 30, 2024, under Article 149. The transition for existing service providers in Article 143(3) ended on July 1, 2026 at the latest.
Can a bank provide stablecoin services without a CASP licence?
Yes. Article 60 allows a credit institution to provide crypto-asset services after notifying its competent authority, and an electronic money institution to provide custody and transfer services for the e-money tokens it issues. Other companies need the authorisation in Article 63.
What is the 200 million euro threshold in MiCA?
Article 23 requires an issuer of an asset-referenced token used as a means of exchange to stop issuing when the estimated daily average exceeds one million transactions and 200 million euro within a single currency area. Article 58(3) applies the same mechanism to e-money tokens denominated in a non-EU currency.
