What are stablecoin issuers?

In the EU a stablecoin that references one currency can be issued only by a credit institution or an electronic money institution. Article 48(1) of MiCA sets two conditions for the issuer: the license, and a crypto-asset white paper notified to the supervisor and published. The issuer tells its supervisor at least 40 working days before the offer (Article 48(6)). Other firms may offer the token to the public only with the issuer's written consent.

An issuer of asset-referenced tokens takes a different path: an authorization under Article 21, which a legal person established in the EU may apply for, or a bank license (Article 16). The rules for stablecoin issuance under both titles have applied since June 30, 2024.

An electronic money institution is a legal person licensed under the E-Money Directive to issue electronic money (Article 2(1) of Directive 2009/110/EC). It needs initial capital of at least EUR 350,000 (Article 4) and own funds of at least 2 percent of its average outstanding e-money (Article 5(3)). It may not take deposits, and the funds it receives for e-money are not deposits (Article 6(2) and (3)).

Unlike a bank, an e-money institution cannot lend out the money it receives. It safeguards those funds (Article 7), and credit it grants for payment services may not come from them (Article 6(1)). For e-money tokens, MiCA adds that at least 30 percent of these funds sit in bank accounts; see what are stablecoins backed by?

Yes. In the EU the list is the interim MiCA register of the European Securities and Markets Authority (ESMA), required by Article 109 of MiCA. In its update of September 24, 2026, the issuers of e-money tokens include 19 e-money institutions and four credit institutions; one entry names no license type. The four banks among the authorized issuers in Europe are Oddo BHF SCA and CACEIS Bank SA in France, Banking Circle S.A. in Luxembourg and Bison Bank S.A. in Portugal (ESMA, interim MiCA register).

The register holds no issuer of asset-referenced tokens.

Stablecoin issuers make money from the assets they hold against the tokens, because holders get no interest. The International Monetary Fund (IMF) writes that issuers "do not directly remunerate holders" and refers to "the returns earned by stablecoin issuers on their reserve assets". Wallet providers and decentralized exchanges may pay users incentives that come close to those returns (IMF, December 4, 2025).

In the EU, MiCA bans such payments: issuers and crypto-asset service providers may not grant interest, and any benefit tied to the holding period counts as interest, including from third parties (Article 50). Redemption of e-money tokens is free of charge (Article 49(6)). Elsewhere, the IMF notes, issuers "often set minimums and charge fees" on redemption.

In Germany an e-money token issuer falls under two laws: "Both MiCAR and the ZAG apply", BaFin writes (BaFin). BaFin supervises e-money issuers under section 4 of the Payment Services Supervision Act (ZAG) and MiCA issuers under section 3 of the KMAG. In the ESMA register, AllUnity GmbH in Frankfurt is the German issuer. BaFin granted it an e-money institution license on July 1, 2025. AllUnity is a joint venture of DWS, Flow Traders and Galaxy and issues the euro stablecoin EURAU (AllUnity, July 2, 2025). In Austria the FMA is the competent authority under section 1 of the MiCA-Verordnung-Vollzugsgesetz; the register lists no Austrian issuer.

Switzerland is outside the EU. A Swiss issuer that accepts deposits from the public on a professional basis generally needs a banking license. Issuers with a default guarantee from a bank need no license but must join a self-regulatory organization as financial intermediaries, and they verify the identity of each holder under the Anti-Money Laundering Act (FINMA, July 26, 2024).

This page gives no legal advice.