Anvesan Sherpa Sign in
Overview Pathfinder Regimes Intelligence Advisory
Regulatory regime

Stablecoin licensing in the European Union

MiCA is the comprehensive regulatory framework for crypto-assets in the European Union. It governs how crypto-assets are issued and traded, and the services built around them, including custody, exchange and transfer. What an organisation needs depends on what it does. This page maps the relevant authorisations, their requirements, timelines and capital thresholds, alongside the companies that currently hold them. The figures come from ESMA’s registers and are updated as those registers change.

RegulatorNational competent authorities, coordinated through ESMA and EBA
LawMiCA (Regulation (EU) 2023/1114)
Registers readESMA registers
Source type1,702 register-sourced, 18 company-reported
Checked21 September 2026

Authorisations in European Union, as at 21 September 2026

Authorisations 1,720 across 10 licence families
Licensed 1,564 of 1,720 authorisations
In the pipeline 6 Applications and in-principle approvals
Ended 150 Refused, withdrawn or lapsed

Authorisations by licence

EEA payment institution authorisation 51% 877
EEA e-money institution authorisation 23% 392
MiCA CASP authorisation 20% 350
EEA small e-money institution registration 3% 60
MiCA EMT issuer 1% 24
Virtual asset service provider registration <1% 7
Other authorisations <1% 5
Payment institution authorisation <1% 3
Money services business registration <1% 1
Electronic money institution authorisation <1% 1

These 1,720 authorisations belong to 1,594 companies. The company-level records are in Atlas Pro.

What those authorisations permit

Issuing a stablecoin477
Holding assets for clients208
Moving value for clients1,188
Scope not stated in the licence42

One authorisation can cover several activities, so these figures overlap.

What each activity needs

Six common activities, and the authorisation each one requires. A business doing more than one may need more than one licence.

Issuing a stablecoin

A stablecoin pegged to one official currency is an e-money token. MiCA does not create a separate issuer licence for it. The issuer must already be an authorised bank or e-money institution and must notify its white paper to the home regulator. A token referenced to anything else falls under the asset-referenced token regime and needs a separate authorisation.

EMT and ART rules have applied since 30 June 2024.

Holding it for someone else

Holding or administering crypto-assets for clients is a MiCA Class 2 service. If the asset is an e-money token and the client can move it to a third party, the activity also falls under the payment-services regime. In that case, a PSD2 authorisation is needed alongside MiCA.

CASP rules have applied since 30 December 2024. The PSD2 overlay has been enforceable since 2 March 2026.

Exchange and on/off-ramps

Exchanging crypto for fiat or another crypto-asset is a MiCA Class 2 service. Operating a trading platform is Class 3. The EBA has confirmed that the exchange itself is not a payment service, so PSD2 does not apply to that leg.

CASP rules have applied since 30 December 2024.

Payments and money transmission

Moving value for someone else requires payment or e-money authorisation. When the asset is an e-money token, the activity also becomes a MiCA transfer service. That means both the payment-services and MiCA permissions can apply.

Both requirements have applied since 2 March 2026.

Cards and consumer spend

There is no separate stablecoin card licence. If the programme stores value, it belongs with an e-money institution. If it issues the payment instrument, it belongs with a payment institution. Many programmes reach the card schemes through a BIN sponsor rather than holding the relevant authorisation themselves.

PSD2 and EMD2 remain the relevant framework.

Cross-border transfer and remittance

Consumer remittance and B2B settlement are payment services under PSD2 regardless of the rail used. Using a stablecoin adds the MiCA transfer-service requirements, and the Travel Rule applies to crypto transfers regardless of size.

The Travel Rule, Regulation (EU) 2023/1113, has applied since 30 December 2024.

The licences: who grants them, how long, what they cost

The statutory clock is the time allowed by law. “Observed” is a range applicants report end to end, including pre-application work outside that clock, and not a figure the regulator publishes. Capital is the regulatory minimum, not legal or advisory fees.

Licence Statutory clockObserved Minimum capitalIn the Atlas
MiCA CASP authorisation 25 + 40 working days 6 to 9 months EUR 50,000 to 150,000 350
MiCA e-money token issuance 20 working days' notice Set by the underlying licence Set by the EMI or bank licence 24
Electronic money institution authorisation 3 months 9 to 18 months EUR 350,000 + 2% of float 1
Payment institution authorisation 3 months 6 to 12 months EUR 20,000 to 125,000 3
Credit institution licence 6 months, capped at 12 18 months and up EUR 5,000,000 Under EMT issuers
MiCA asset-referenced token issuer authorisation 25 + 60 working days No observed authorisations EUR 350,000 or 2% of reserves EBA register, not read
National VASP registration Closed to new entrants Closed Not applicable 7

Application fees are set by each national competent authority and are not harmonised across the union. Anvesan has not sourced them state by state and publishes no figure it cannot cite.

MiCA CASP authorisation

350 in the Atlas
Who grants it
The national competent authority in your home member state. The authorisation can be passported across the EEA, with ESMA maintaining the EU register.
What triggers it
Providing a MiCA crypto-asset service to clients in the EU, including custody, exchange, trading-platform operation, transfer, order execution, placing, advice or portfolio management.
Legal basis
MiCA, Regulation (EU) 2023/1114, Title V, Articles 59 to 63; Annex IV for capital requirements.

Where the crypto-asset is an e-money token and the service moves it to or from a third party, a PSD2 authorisation is required as well. The two sets of capital apply cumulatively, with no offset.

Statutory clock 25 + 40 working days

The NCA has 25 working days to determine whether the application is complete. Once complete, it has 40 working days to grant or refuse the authorisation. The decision is then notified within five working days.

What it takes in practice 6 to 9 months

The statutory clock starts only once the application is complete. Pre-application work, requests for further information and the completeness process fall outside it. In practice, applicants report around six to nine months end to end.

Class 1transfer, order execution, reception and transmission, placing, advice, portfolio management EUR 50,000
Class 2custody and administration; exchange for funds; exchange for other crypto-assets EUR 125,000
Class 3operating a trading platform EUR 150,000

Or one quarter of the previous year's fixed overheads, whichever is higher.

Application fee MiCA sets no application fee. Each NCA sets its own, and several also levy an annual supervisory charge. Not yet sourced per state.

MiCA e-money token issuance

24 in the Atlas
Who grants it
There is no separate MiCA issuer licence. The issuer must already be an authorised bank or e-money institution and must notify its white paper to the home regulator.
What triggers it
Offering an e-money token that refers to a single official currency in the EU, or seeking to admit that token to trading.
Legal basis
MiCA, Regulation (EU) 2023/1114, Title IV, Articles 48 to 58, with white-paper notification under Article 51.

A stablecoin referencing a basket, a commodity or more than one currency is an asset-referenced token, and takes the separate ART authorisation below.

Statutory clock 20 working days' notice

The white paper must be notified to the NCA at least 20 working days before publication. The regulator does not approve it in advance.

What it takes in practice Set by the underlying licence

The real wait is the e-money or bank authorisation underneath. The white-paper notice adds four weeks to a route that already runs months.

Carried by the underlying licencee-money institution initial capital, or a credit institution's EUR 350,000 or EUR 5,000,000

The reserve is separate from capital: full backing, segregated, redeemable at par on demand at no fee, and no interest paid to holders.

Application fee No fee for the notification itself. The fee is on the licence underneath.

Electronic money institution authorisation

1 in the Atlas
Who grants it
The national competent authority in the home member state. An EMI can passport its authorisation across the EEA.
What triggers it
Issuing e-money, including MiCA e-money tokens, or holding stored value on behalf of customers.
Legal basis
E-Money Directive 2009/110/EC; authorisation procedure under PSD2, Directive (EU) 2015/2366, Article 12.

Under PSD3 and the PSR, e-money institutions become a sub-category of payment institution and existing EMIs will have to re-apply within the transition.

Statutory clock 3 months

The NCA informs the applicant whether the authorisation is granted or refused within three months of a complete application.

What it takes in practice 9 to 18 months

The statutory period starts once the application is complete. Reaching completeness is the long part: governance, safeguarding, an audited business plan, and fit-and-proper assessments of every controller.

Initial capitalat authorisation and at all times EUR 350,000
Ongoing own fundsMethod D, where it exceeds initial capital 2% of average outstanding e-money

Customer funds are safeguarded separately from own funds and are not part of this figure.

Application fee Set nationally. Not yet sourced per state.

Payment institution authorisation

3 in the Atlas
Who grants it
The national competent authority in the home member state. A payment institution can passport its authorisation across the EEA.
What triggers it
Executing payment transactions, money remittance, acquiring, issuing payment instruments, or moving e-money tokens on behalf of clients.
Legal basis
PSD2, Directive (EU) 2015/2366, Articles 5 to 12; initial capital under Article 7.

Since 2 March 2026 this is the second authorisation a CASP needs if it custodies or transfers e-money tokens.

Statutory clock 3 months

The NCA informs the applicant whether the authorisation is granted or refused within three months of a complete application.

What it takes in practice 6 to 12 months

The statutory period starts once the application is complete. As with the e-money institution, assembling that file is where most of the time goes.

Money remittance only EUR 20,000
Payment initiation services EUR 50,000
Executing transactions, acquiring, issuing instruments EUR 125,000

Ongoing own funds are calculated under Method A, B or C and can exceed the initial figure as volume grows.

Application fee Set nationally. Not yet sourced per state.

Credit institution licence

Who grants it
The national competent authority prepares the file; the ECB grants it under the Single Supervisory Mechanism.
What triggers it
Taking deposits from the public. Also the alternative route to issuing a MiCA e-money token.
Legal basis
CRD, Directive 2013/36/EU, Articles 8 to 15; CRR, Regulation (EU) 575/2013.
Statutory clock 6 months, capped at 12

A decision within six months of a complete application, and in any event within twelve months of receipt.

What it takes in practice 18 months and up

The longest route on this page, and the one a few stablecoin issuers take anyway for the deposit base and the direct access to payment systems.

Initial capitalplus Pillar 1 and Pillar 2 requirements on an ongoing basis EUR 5,000,000

Risk-weighted requirements on top, which for a stablecoin balance sheet are the larger number.

Application fee Set nationally, plus ECB supervisory fees once authorised.

MiCA asset-referenced token issuer authorisation

Who grants it
The home NCA, after opinions from the EBA and the ECB. The EBA supervises issuers designated significant.
What triggers it
Issuing a token that references a basket, a commodity, or anything other than one single official currency.
Legal basis
MiCA, Regulation (EU) 2023/1114, Title III, Articles 16 to 47; own funds under Article 35.
Statutory clock 25 + 60 working days

25 working days for completeness, then 60 working days for the reasoned draft decision, with the ECB and the EBA giving opinions inside that window.

What it takes in practice No observed authorisations

The dataset is still too small to give a meaningful observed timeline: ART issuers are registered by the EBA, which this dataset does not yet read. The route is also rare, because most stablecoins in the market reference a single currency and take the EMT path instead.

Flat floorat authorisation and at all times EUR 350,000
Or 2% of average reserve assetsas the token grows whichever is highest
Or one quarter of fixed overheads whichever is highest

A significant ART carries 3% of average reserve assets instead of 2%.

Application fee Set nationally.

National VASP registration

Closed route 7 in the Atlas
Who grants it
National AML registers, member state by member state. Never passportable.
What triggers it
The pre-MiCA route. Grandfathering ended no later than 1 July 2026.
Legal basis
National AML regimes under AMLD5, superseded by MiCA.

We keep this route here because Atlas still tracks the records, and because an old registration is often the first thing a counterparty finds.

Statutory clock Closed to new entrants

No member state grants these for crypto-asset services any more.

What it takes in practice Closed

Anything still trading on one of these alone is operating without authorisation.

Capital requirement Not applicable

Application fee Not applicable. The route is closed.

What to watch

Regulatory changes only: what is being decided, by whom, and when. Company-level licence changes are tracked in Atlas Pro. Reviewed 9 September 2026.

Ahead

30 September 2026 Consultation closes

The MiCA review consultation closes

The Commission opened a targeted consultation on the MiCA review on 20 May 2026 and extended the deadline from 31 August to 30 September. The report to Parliament and Council under Articles 140 and 142 follows, due by 30 June 2027, and may carry a legislative proposal with it.

What changes The consultation covers multi-issuance, DeFi, staking, and whether the current CASP classes should remain unchanged.

European Commission, targeted consultation document

By end 2026 Open question

Whether a third-country stablecoin can be fungible with its EU twin

Parliament voted 390 to 86 on 9 July 2026 to allow multi-issuance with safeguards. The ECB's non-paper of 10 April 2026 reads MiCA as not permitting third-country multi-issuance, and the ESRB's recommendation adopted on 25 September 2025 and published on 20 October 2025 asked for third-country equivalence assessments to be finished by the end of 2026. The outcome is still open.

What changes The outcome will determine whether the largest dollar stablecoins can be offered in the EU at all, or only through separately reserved EU issuance.

ESRB recommendation adopted 25 September 2025, published 20 October 2025

Expected in 2026 Awaiting publication

PSD3 and the PSR reach the Official Journal

The final texts were agreed on 23 April 2026, a day after COREPER endorsed them. Publication was expected mid-2026 and has not happened yet. The PSR enters into force 20 days after publication and applies 21 months later; PSD3 is transposed nationally on the same clock.

What changes E-money institutions become a sub-category of payment institutions. Existing EMIs will need to transition to the new category during the implementation period.

European Parliament, legislative train: payment services regulation · European Parliament, legislative train: PSD3

Target: end 2026 In trilogue

Digital euro trilogues aim to conclude

ECON adopted its position on 23 June 2026 by 43 votes to 14 with one abstention, and the plenary gave the negotiating mandate on 9 July 2026 by 416 to 169 with 22 abstentions. The three institutions are aiming to finish this year. The ECB plans a twelve-month pilot in the second half of 2027.

What changes A public euro rail distributed through banks, payment firms and regulated crypto firms changes the commercial case for a private euro e-money token.

European Parliament, legislative train: digital euro

Recently landed

2 March 2026 In force

Custody and transfer of an e-money token now need a PSD2 licence as well

The EBA's no-action period under Opinion EBA/Op/2025/08 of 10 June 2025 ended, after a follow-up opinion published on 12 February 2026 told competent authorities what to do at the end of it. A CASP that custodies transferable e-money tokens, or moves them for clients, needs a payment institution or e-money institution authorisation alongside its MiCA one.

What changes Two authorisations, two sets of capital, applied cumulatively with no offset. A CASP that custodies or transfers e-money tokens without the PSD2 side is operating outside its permissions.

EBA Opinion EBA/Op/2025/08

1 July 2026 Route closed

MiCA grandfathering ended

The transition for firms operating on national VASP registrations closed. No member state may extend it further.

What changes A national registration no longer permits crypto-asset services anywhere in the EU. Firms still relying on one are unauthorised, not transitioning.

ESMA, Markets in Crypto-Assets Regulation

Questions this page answers

How many companies hold a stablecoin-related licence in the European Union?

Atlas tracks 1,720 authorisations across 1,594 companies in the EU, based on ESMA's registers and checked on 21 September 2026. Of those, 1,564 are licensed, 6 are in the pipeline, and 150 have ended.

What licence does a stablecoin issuer need in the EU?

For an e-money token, the issuer must already be an authorised bank or e-money institution and must notify its white paper to the home regulator. A token referenced to a basket, commodity or other asset falls under the separate asset-referenced token regime and requires its own authorisation.

How long does a MiCA CASP licence take?

The statutory clock is 25 working days for the completeness check and 40 working days for the decision. In practice, applicants report around six to nine months end to end because pre-application work and information requests fall outside the statutory clock.

How much capital does a MiCA authorisation require?

EUR 50,000, EUR 125,000 or EUR 150,000 depending on the services provided. For custody and exchange, the minimum is EUR 125,000. Operating a trading platform requires EUR 150,000. In every class the requirement becomes one quarter of the previous year's fixed overheads where that is higher.

What does a MiCA licence cost to apply for?

MiCA does not set a single EU-wide application fee. Each national competent authority sets its own fees, and some also charge annual supervisory fees. Anvesan has not yet sourced these state by state, so we do not publish an estimate here.

Does a MiCA licence work across the whole EU?

Yes, through passporting. A CASP authorised in one member state can provide its authorised services across the EEA through the passporting process. Payment institutions and e-money institutions can also passport their authorisations. ESMA therefore publishes the EU register as a single list even though the authorisations are granted nationally.

How these numbers are made

Registers read
ESMA's register of authorised crypto-asset service providers and its register of e-money token issuers.
Cadence
Checked daily. Changes are recorded when they appear in the register, together with the date they were seen. Last checked 21 September 2026.
Licence detail reviewed
10 September 2026. Counts are refreshed daily. Licence terms, timelines and capital thresholds are reviewed separately because they come from the underlying rules rather than the register.
Known gap
Asset-referenced token issuers are registered by the EBA, not ESMA, and are not yet included in this dataset. Where a figure is unavailable, we mark it as missing rather than estimate it.
Corrections
research@anvesan.org