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An e-money token (EMT) is a stablecoin that refers to one official currency, such as the euro or the US dollar. Under MiCA, the EU crypto-assets regulation, only e-money institutions (EMIs) and banks may issue one. Most EMTs are supervised by the issuer's home regulator. Once a token grows large enough to be classed as significant, the European Banking Authority (EBA) joins that supervision and the issuer takes on stricter capital, reserve and liquidity rules.
That has now happened for the first time. The EBA classified USDC as significant on 14 October 2026, and from 12 November 2026 USDC's issuer in the EU, Circle Internet Financial Europe SAS, is under the dual supervision of the EBA and France's ACPR. This guide explains the significance test, the steps to a decision and what changes for the issuer, so EMIs and banks with growing tokens can plan for it. Our guide to issuing an EMT or ART under MiCA covers authorisation and the white paper.
| Date | Event |
|---|---|
| 30 June 2024 | MiCA rules for issuers of asset-referenced and e-money tokens apply |
| 14 October 2026 | EBA classifies USDC as the first significant EMT; 45 EMTs had been notified in the EU |
| 14 October 2026 | EBA signs a memorandum of understanding with the New York State Department of Financial Services on USDC supervision |
| 12 November 2026 | Dual supervision of USDC by the EBA and the ACPR begins |
| Every year | EBA reassesses whether each significant token still meets the criteria |
The EBA said direct supervision of own funds, the reserve of assets, liquidity requirements and recovery and redemption plans moves from the ACPR to the EBA. The ACPR remains responsible for governance, qualifying holdings, fit and proper assessment, outsourcing and conflicts of interest. The two authorities work through a supervisory college, under Articles 117 and 119 of MiCA.
Article 56 of MiCA applies to e-money tokens the criteria in Article 43(1). A token is classified as significant where at least three are met. Delegated Regulation (EU) 2024/1506 sets out how each indicator is measured.
| Criterion | Threshold |
|---|---|
| Number of holders | More than 10 million |
| Value issued, market capitalisation or size of the reserve | More than EUR 5 billion |
| Average daily number and value of transactions | More than 2.5 million transactions and EUR 500 million a day |
| Issuer is a designated core platform | Issuer provides core platform services designated under the Digital Markets Act |
| International significance | Scale of the issuer's activity worldwide, including use for payments and remittances |
| Interconnectedness | Links between the token or its issuer and the financial system |
| Multiple products | The issuer also issues another token and provides at least one crypto-asset service |
Four criteria are numbers and three are judgements, so a token can become significant without crossing every numeric line. A large dollar token used widely outside the EU, for example, can meet the international significance test alongside two numeric thresholds.
The process follows Article 43, applied to EMTs by Article 56. National regulators report on each token to the EBA and the European Central Bank at least twice a year. Where at least three criteria are met during the period of the first report after notification, or during two consecutive reports, the EBA prepares a draft decision.
| Step | Timing |
|---|---|
| Draft decision sent to the issuer, its regulator and the ECB | After the criteria are met |
| Issuer and authorities submit written observations | 20 working days |
| Final decision | Within 60 working days of the draft |
| Supervisory responsibilities transferred | Within 20 working days of the final decision |
| Reassessment | Every year; a token that no longer qualifies can be declassified by the same steps |
An issuer can also ask for significant status when it applies or notifies, under Article 57, where it expects the token to qualify. That is unusual, but it can suit a bank group launching a token through an existing large distribution network.
Article 58 sets the extra duties for an EMI issuing a significant EMT. In short, the e-money directive's capital and safeguarding rules give way to the stricter MiCA rules written for asset-referenced tokens.
| Area | Non-significant EMT issued by an EMI | Significant EMT |
|---|---|---|
| Own funds | E-money directive method: at least 2% of average outstanding e-money, above the EUR 350,000 initial capital | Highest of EUR 350,000, a quarter of fixed overheads and 3% of average reserve assets (Articles 35 and 45(5)) |
| Extra own funds | As set by the home regulator | Regulator may add up to 20% for higher risk; stress test results trigger 20% to 40% more (Article 35(3) and (5)) |
| Reserve of assets | E-money directive safeguarding, with at least 30% of funds in bank deposits (Article 54) | MiCA reserve, custody and investment rules (Articles 36 to 38) |
| Reserve audit | As required by the home regulator | Independent audit every six months from the classification date |
| Liquidity | General liquidity management | Liquidity management policy and regular liquidity stress tests (Article 45(3) and (4)) |
| Remuneration | General governance rules | Remuneration policy that supports sound risk management (Article 45(1)) |
| Custody by others | No specific duty | Token must be holdable by different crypto-asset service providers on fair terms (Article 45(2)) |
The own funds change is the largest in money terms. The base moves from outstanding e-money to the reserve of assets, and the rate from 2% to 3%, before any add-on. An issuer with EUR 6 billion of reserves would need at least EUR 180 million of own funds on that measure alone, and more after stress testing. The text of Article 58 and Article 45 is on ESMA's interactive rulebook. Home regulators may also apply any of these duties to a non-significant token where the risks call for it (Article 58(2)).
Nothing changes for people and businesses that hold or use USDC. The token stays an e-money token issued by an authorised EMI, and holders keep the right to redeem at par at any time, free of charge. Classification adds supervision and capital at the issuer; it does not restrict who may hold or transfer the token.
For crypto-asset service providers, USDC remains a MiCA-compliant token they may list and hold for clients. That matters because ESMA has set 8 January 2027 as the date by which platforms must clear exposures to stablecoins that do not comply with MiCA. A significant classification is the opposite signal: the token is inside the regime and under the closest supervision it offers.
For EMIs and banks that issue their own tokens, USDC is the template. The EBA has shown it will apply the criteria as written, that dual supervision starts within weeks of the decision, and that it will work with non-EU supervisors where a token is issued in more than one jurisdiction, as its arrangement with the New York State Department of Financial Services shows. A euro or dollar token that grows through payments, remittances or exchange listings should expect the same path once it meets three criteria.
Distributors also carry their own duties. A platform that offers an EMT to EU clients needs MiCA CASP authorisation, and a payment business that moves EMTs for customers needs the right payment permissions as well.
| Area | Supervisor |
|---|---|
| Own funds | EBA |
| Reserve of assets | EBA |
| Liquidity requirements | EBA |
| Recovery and redemption plans | EBA |
| Governance | Home regulator |
| Qualifying holdings and fit and proper | Home regulator |
| Outsourcing and conflicts of interest | Home regulator |
| E-money institution licence and payment services | Home regulator |
Dual supervision means two sets of questions, two reporting lines and a supervisory college. Issuers should agree a single data set for reserves and liquidity that satisfies both authorities, and keep board minutes showing decisions on both sides.
Few issuers will cross the line soon, but a fast-growing euro or dollar token can meet three criteria quickly, and the decision can follow a single reporting period. Five steps make the transition manageable.
Issuers that start with these steps, including through our stablecoin licensing practice, face a change of supervisor rather than a rebuild. The stablecoin issuers index tracks which issuers hold which licences.
Buckingham Capital Consulting has handled payments, e-money and cryptoasset licensing since 2013, obtaining authorisations for firms including Nexpay, Orbital, Dzing Finance and Hryze. We support EMIs and banks issuing e-money tokens with MiCA notifications and white papers, reserve and custody design, own funds and liquidity models, stress testing and recovery and redemption plans. We also obtain the underlying e-money licence, such as a France EMI licence, and MiCA CASP authorisation for distribution. Contact us to discuss your token.
An e-money token that the EBA classifies as significant because it meets at least three of the seven criteria in MiCA Article 43(1), applied to EMTs by Article 56. Its issuer then faces stricter capital, reserve and liquidity rules and EBA supervision.
USDC, issued in the EU by Circle Internet Financial Europe SAS. The EBA classified it on 14 October 2026, with dual supervision from 12 November 2026.
More than 10 million holders; more than EUR 5 billion issued, in market capitalisation or in reserves; more than 2.5 million transactions and EUR 500 million a day; plus qualitative tests such as designation under the Digital Markets Act, international significance and interconnectedness.
The highest of EUR 350,000, a quarter of fixed overheads and 3% of the average reserve of assets, with possible add-ons of up to 20% for risk and 20% to 40% after stress testing.
No. For significant EMTs the EBA supervises own funds, reserves, liquidity and recovery and redemption plans. The national regulator keeps governance, qualifying holdings, fit and proper, outsourcing and conflicts of interest.
Yes. The EBA reassesses every year and can declassify a token that no longer meets the criteria, using the same notice and decision steps.
Get in touch: +44 7563 115980 (phone and WhatsApp) or [email protected].
This article is general information, not legal advice. Requirements change, and the regulator’s own publications take precedence.
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