Who Will Be Able to Issue Stablecoins in the EU After June 2026? An In-Depth Analysis on the Eve of Full Implementation of MiCA

As June 30, 2026, approaches, the full implementation of the EU’s Markets in Crypto-Assets Regulation (MiCA) is entering its final countdown. This date marks the official end of the “grandfather clause” (transitional arrangements) for crypto asset service providers (CASPs). Prior to this, the market has undergone profound structural adjustments. The most notable signals come from the stablecoin sector: since the end of 2024, when MiCA’s provisions on asset-referenced tokens (ART) and electronic money tokens (EMT) took effect, mainstream trading platforms have gradually delisted non-compliant stablecoins like Tether (USDT), shifting instead to compliant currencies licensed as electronic money institutions (EMI), such as USDC and EURC.

Meanwhile, the European Banking Authority (EBA) issued guidance in February 2026, clarifying another key transition period—the nine-month grace period overlapping MiCA and the Payment Services Directive (PSD2)—which will end on March 2, 2026. During this period, CASPs involved in EMT payment services must obtain dual authorization or partner with authorized institutions. These changes collectively paint a clear picture: EU crypto regulation has shifted from “rule-making” to “rule enforcement.”

Why Have Stablecoins Become the Core Focus of This Regulatory Reshaping?

Stablecoins, especially EMTs, have become central to MiCA regulation because their functions are deeply intertwined with traditional currencies and payment systems. MiCA strictly distinguishes between ART (asset-backed basket tokens) and EMT (single fiat-backed tokens), limiting EMT issuance to EU-licensed credit institutions or electronic money institutions (EMI). The underlying logic is “same business, same risk, same regulation.” When EMTs are used for daily payments, their activity essentially constitutes a payment service, which must comply with PSD2 rules. The EBA further clarified in February 2026 that even transfers between wallets, or EMT transfers between user-first-party wallets, could be deemed payment transactions, triggering PSD2 licensing requirements. This means that holding only a MiCA license is insufficient for comprehensive EMT operations; regulators are effectively embedding crypto activities into the existing financial regulatory framework through this mechanism.

What Are the Compliance Costs and Structural Implications of Dual Regulation?

While the combined regulation of MiCA and PSD2 aims to mitigate risks, it also imposes significant compliance costs and structural challenges on the industry. First, license costs are effectively doubled. A CASP seeking to provide EMT payment services now needs to apply for both MiCA authorization and PSD2-based Payment Institution (PI) or Electronic Money Institution (EMI) licenses, or partner with already licensed entities. This entails not only financial costs but also substantial time and organizational resource investments. Second, operational complexity increases. According to ESMA clarifications, CASPs must ensure complete segregation of customer assets and proprietary assets at the wallet address level, and cannot use broad user terms to deny rights to assets like forks or airdrops. For platforms relying on complex internal settlement systems and global liquidity pools, this necessitates a major overhaul of technical architecture and user agreements. It is anticipated that these high compliance barriers will lead to market concentration among top players, while smaller innovative teams may be forced out of the EU market or shift to unregulated decentralized protocols due to prohibitive costs.

Does This Mean a Shift in Market Dominance in the Web3 Industry?

The full implementation of MiCA is profoundly reshaping the power dynamics within the EU Web3 industry. One immediate manifestation is the shift in stablecoin market share. Compliant currencies like USDC and EURC now dominate the EU market, while issuers that fail or refuse to adapt to MiCA are marginalized. This is effectively a market clearing. The view is that this is not just a token replacement but a phased victory of “regulatory credibility” over “network effects.” For exchanges and CASPs, the competitive barrier has shifted from “number of assets listed” to “depth of compliant architecture.” Those capable of building “distributed licensed” networks—platforms with deep compliance across multiple core jurisdictions (EU, Middle East, Asia-Pacific)—will enjoy greater operational resilience and institutional trust. The EU passport mechanism’s advantages will be further amplified: once authorized under MiCA in one member state, CASPs can operate across the entire EU economic area, attracting more non-EU capital through acquisitions or establishing EU entities to obtain this “single market passport.”

How Might Market Participants Evolve Over the Next Six Months?

Looking ahead over the next six months until the transition period ends, the market will evolve along three clear paths. The first is the expansion of “compliance pioneers.” Already dual-licensed institutions will begin active marketing, leveraging regulatory certainty to attract institutional clients with strict compliance requirements. Their focus will shift from “whether compliant” to “how to leverage compliance for product advantages.” The second is the challenging sprint of “applicants in process.” CASPs that have submitted PI/EMI applications but have not yet been approved face limited grace periods from the EBA, with strict restrictions such as halting marketing and prohibiting onboarding new clients. This group is likely to be the most tense in the coming months, needing to rapidly address regulatory inquiries while maintaining existing operations—time is tight. The third is the passive exit of “non-acting” entities. CASPs that fail to submit valid applications or cannot meet requirements will be required by regulators to wind down services and facilitate client withdrawals in an orderly manner. Overall, after the transition period, the list of active service providers within the EU is expected to be significantly reduced.

What Hidden Risks Exist in the Era of Full Compliance?

Despite the clarity brought by MiCA, its full implementation still harbors multiple risks. First, systemic risks. The European Central Bank (ECB) warned in 2025 that as EMTs grow in scale, they could trigger bank deposit withdrawals, weakening the stability of bank funding bases. Large-scale redemptions and the forced sale of stablecoin reserves could impact short-term government bond markets, leading to liquidity spirals. Second, regulatory arbitrage and geopolitical risks. While MiCA creates a unified framework within the EU, global regulation remains fragmented. Non-compliant stablecoins might continue to penetrate the EU via DeFi protocols or non-custodial wallets, creating new gray areas. Divergences in regulatory policies between the US, Asia, and the EU could fragment global liquidity, complicate cross-border operations, and increase legal risks. Third, technical risks at the enforcement level. ESMA’s requirement to adopt high-standard data formats like ISO 20022 for reporting and record-keeping places high demands on CASPs’ IT systems and data governance. Technical failures or data breaches could directly lead to compliance violations.

Summary

The full implementation of MiCA in the EU signifies more than just a deadline; it marks the end of an old era in the global crypto industry and the beginning of a new one. In this new order, facts have replaced ambiguity, and compliance costs have replaced trial-and-error. The core of MiCA is not about prohibition but about “integration”—using a rigorous financial regulatory language to translate and connect previously outside the system’s scope into mainstream financial infrastructure. It is anticipated that future participants who deeply understand this language and restructure their business processes, risk management, and governance accordingly will gain a “passport” for compliant operation within the EU’s unified market and enjoy a first-mover advantage for long-term growth. For the entire industry, balancing the certainty of mainstream finance with the preservation of decentralization remains an ongoing challenge.

FAQ

Q1: When exactly will MiCA be fully implemented?

A: According to EU regulations, for crypto asset service providers (CASPs) that provided services before December 30, 2024, the transition period can last until July 1, 2026 (i.e., until June 30, 2026). Starting July 1, 2026, all CASPs operating in the EU must obtain full MiCA authorization.

Q2: What is EMT, and what special requirements does it have under MiCA?

A: EMT (Electronic Money Token) refers to stablecoins pegged to a single fiat currency (e.g., euro, USD). MiCA imposes strict rules: issuers must be EU-licensed credit or electronic money institutions (EMI). Additionally, if CASPs provide EMT-related payment services (like transfers), they may trigger PSD2 licensing requirements, resulting in dual regulation.

Q3: Why is USDT facing delisting in the EU while USDC is not?

A: The key lies in whether the issuer meets MiCA compliance. USDC’s issuer, Circle, has obtained an EMI license in France, with transparent reserves and audit reports meeting MiCA standards. USDT’s issuer, Tether Limited, has not obtained relevant licenses in the EU, and its reserve disclosures and compliance systems do not yet meet MiCA requirements, leading major EU exchanges to deem it non-compliant and delist it.

Q4: Will my personal wallet transfers in the EU be affected after MiCA takes effect?

A: The regulation primarily targets service providers (CASPs), not individual users. The EBA clarified that even EMT transfers between user-first-party wallets facilitated by CASPs could be considered payment services, requiring authorization. If your CASP lacks the necessary payment service license, it may no longer process such transfers for you. However, peer-to-peer transfers between personal non-custodial wallets are generally outside CASP regulation.

Q5: What should new projects aiming to enter the EU market do now?

A: First, clarify your business scope—whether it involves ART, EMT, or other crypto assets. Then, start preparing for compliance by developing whitepapers aligned with MiCA requirements, establishing governance and AML frameworks. Finally, engage with regulators early, submit complete and high-quality license applications. Given the processing times, now is the critical window to initiate the application process.