What is an E-Money Token (EMT)?
An E-Money Token (EMT) is a type of crypto-asset that maintains a stable value by referencing a single official fiat currency, as defined in Article 3(1)(7) of the EU's MiCA regulation. The key word is "single." A token pegged 1:1 to the euro is an EMT. A token pegged 1:1 to the US dollar is also an EMT. A token pegged to a basket of currencies is not — that is an Asset-Referenced Token (ART) under a different MiCA category.
EMTs apply from June 30, 2024. Since that date, offering an EMT to EU users without authorization has been prohibited.
What stablecoins are EMTs?
Any fiat-pegged stablecoin offered to EU users falls under the EMT framework, regardless of which currency it references. Common examples:
- EURC: Circle's euro stablecoin. Circle obtained EMI authorization in France through the ACPR in July 2024, becoming the first global issuer authorized under MiCA
- USDC: Also issued by Circle under the same French EMI authorization
- EURCV: Issued by Societe Generale-Forge under its French credit institution license
- EURI: Issued by Banking Circle under EMI authorization in Luxembourg
- USDT: Tether did not seek EMT authorization. Tether's CEO cited the 60% bank deposit requirement for significant EMTs as incompatible with Tether's reserve mix. USDT was subsequently delisted from EU-regulated venues
Who can issue an EMT?
Only two types of entity can issue EMTs in the EU:
- Credit institutions authorized under EU banking law (CRR, Regulation 575/2013)
- E-money institutions (EMIs) authorized under the E-Money Directive (Directive 2009/110/EC)
This is more restrictive than the ART category. ART issuers can be other types of legal entity with direct MiCA authorization. EMT issuers must work within existing financial institution frameworks rather than obtaining a standalone crypto license.
Before offering an EMT, the issuer must notify a white paper to the national competent authority. This must happen at least 40 working days before the offer date. The white paper covers reserve composition, redemption rights, technology, and risk disclosures. In March 2025, BaFin issued the EU's first MiCA cease-and-desist against a stablecoin issuer that omitted reserve attestations from its white paper.
What are the reserve requirements for EMTs?
EMT issuers must hold reserves equal to 100% of outstanding token supply at all times. Reserves must be held in secure, low-risk assets. For EMTs designated as "significant," at least 60% of reserves must be held in bank deposits. This 60% requirement was the specific rule that Tether cited when declining to seek EU authorization.
Holders have an unconditional right to redeem their EMTs at par value at any time. This distinguishes EMTs from most other crypto-assets and aligns them with how electronic money works under existing EU law.
Can EMTs pay interest?
No. EMTs cannot pay interest or any other benefit linked to the holding period. This prohibition exists specifically to prevent EMTs from competing with bank deposits or being used as investment instruments. An EMT that generates yield for its holder would cross into deposit territory and require banking authorization rather than EMI authorization.
This is an important distinction for platforms building yield products. A stablecoin that generates yield, such as those covered in stablecoin yield, is not an EMT under MiCA.
What is a "significant" EMT?
An EMT is designated "significant" when it crosses any one of three thresholds:
- More than 10 million holders
- Daily transaction volume above EUR 200 million
- Market capitalization above EUR 1 billion
Once significant, supervision transfers from the national competent authority to the European Banking Authority (EBA) directly. The EBA can cap new issuance and impose enhanced liquidity requirements. This is the mechanism MiCA uses to limit the systemic risk of widely adopted stablecoins, particularly USD-pegged tokens that could displace the euro in EU payments.
How do EMTs differ from ARTs?
Does converting between EMTs require its own authorization?
Yes. Converting between EMTs, or between an EMT and euros, is a separate regulated activity from issuing the token itself.
Due is authorized by Spain's CNMV as a Crypto-Asset Service Provider for exactly this: exchanging crypto-assets for funds and for other crypto-assets, passported across 30 EEA markets.
This covers the conversion leg of a payment flow. It does not extend MiCA compliance to a platform's other regulated activities, which remain the platform's own responsibility.
