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Start with the legal issuer, not the token’s brand, exchange listing, or a marketing claim. A token that references the euro is generally an e-money token (EMT) under the Markets in Crypto-Assets Regulation (MiCA). A defensible check matches the issuer’s exact legal name and legal entity identifier (LEI), confirms the issuer appears in the European Securities and Markets Authority (ESMA) MiCA register, verifies that it is authorised as a credit institution or electronic money institution (EMI) in the relevant national register, and reconciles the current white paper, offer dates and any warnings.
An ESMA register entry or published white paper is evidence that a filing exists; it is not an approval of the white paper’s contents. Treat the result as verified only when the legal entity, licence, token classification, dates and status all agree.
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The seven-part verification test
Use this sequence for any euro-referenced stablecoin offered to the public in the European Union or proposed for admission to trading:
- Identify the legal issuer. Record its exact registered name, jurisdiction, LEI if shown, token name and issuer website. Separate the issuer from a distributor, exchange or other crypto-asset service provider (CASP).
- Classify the token. A token referencing an official currency of a Member State, such as the euro, is generally an EMT. A token referencing a basket or other assets may instead be an asset-referenced token (ART).
- Search the ESMA MiCA register. Match the issuer and token to the EMT record, white paper, offer or admission date and underlying authorisation details.
- Check the underlying national licence. An EMT issuer must be authorised as a credit institution or EMI. Confirm that authorisation independently in the competent authority’s current register.
- Read the current white paper. Compare its legal entity, token name, currency reference, rights, redemption language, competent authority and version date with the registers.
- Reconcile dates and status. Note the authorisation date, intended or actual offer date, the 40-working-day notification requirement and any withdrawal or precautionary measure.
- Escalate inconsistencies. If an LEI, licence number, issuer name, token name or status differs, stop the conclusion and ask the competent authority or qualified EU regulatory counsel.
Keep a dated copy or export of every register result and white-paper version. Registers and issuer pages can change, so a later reviewer must be able to see exactly what you checked.
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Why the legal issuer matters more than the exchange
MiCA places the core EMT obligation on the person making the offer or seeking admission to trading. The exchange through which you buy the token may be a CASP, and a separate distributor may handle marketing or customer interfaces. Neither relationship proves that the entity that issued the token holds the required banking or e-money authorisation.
Capture the issuer’s complete legal name exactly as displayed in the white paper and register. Trading symbols, logos and abbreviated corporate names are not reliable identifiers. Where available, copy the LEI as well; it is a strong way to distinguish companies with similar names. Record the home Member State and the competent authority named in the disclosure.
A claim such as “available on regulated exchanges” answers a different question. It may indicate something about the venue’s CASP status, but it does not establish that the token issuer is authorised under MiCA Article 48.
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Collect the identity fields
Before opening a register, create an identity record with these fields:
- Commercial token name and ticker.
- Exact legal issuer name, including corporate suffix.
- Country of incorporation and stated home Member State.
- LEI, if the issuer provides one.
- Issuer website and the page hosting legal disclosures.
- Name of any distributor, exchange or CASP separately involved.
Use the white paper and formal terms, not only an exchange’s asset page. If the issuer uses one company for reserves and another for issuance, identify which entity is legally the issuer of the EMT. A reserve custodian, payment processor or parent company is not automatically the issuer.
Resolve name changes and group structures
Corporate reorganisations can leave an old name on a cached exchange page while a current register shows a new legal name. Compare the LEI, registered address and licence number. A parent company’s authorisation does not automatically extend to a subsidiary. If the token’s documents alternate between entities, treat that as an unresolved discrepancy until the competent authority or an updated filing explains it.
Step 2: decide whether the token is an EMT or an ART
Euro reference: the EMT presumption
MiCA Article 48 states that an e-money token referencing an official currency of a Member State is deemed to be offered to the public in the Union. A token designed to maintain a one-to-one reference to the euro therefore normally follows the EMT route, even when it is marketed as a “stablecoin” or “digital cash.” The commercial label does not determine the legal category.
When an ART analysis may be needed
If the token references a basket of currencies, commodities, crypto-assets or other values instead of one official currency, test the ART definition and the Article 16 authorisation route. Some products contain several reference mechanisms or reserve assets; read the white paper’s stabilisation and reference language rather than inferring the category from its ticker.
Borderline cases should be documented. Write down the reference asset, how the target value is calculated, and the issuer’s own classification. If those descriptions conflict, do not treat an EMT register hit as conclusive until the competent authority clarifies the legal category.
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Why classification changes the check
EMTs require an issuer authorised as a credit institution or EMI and a notified, published crypto-asset white paper. ARTs have a different authorisation process. The Article 16 text says an authorisation granted by the competent authority to the relevant ART issuer is valid throughout the Union. Do not use an ART authorisation as a substitute for the EMT licence test, or vice versa.
Step 3: search the ESMA MiCA register
What Article 109 requires
MiCA Article 109 requires ESMA to maintain a public register covering crypto-asset white papers for assets other than ARTs and EMTs, issuers of ARTs, issuers of EMTs and CASPs. For a euro stablecoin, select the EMT issuer section and locate the legal entity rather than searching only the commercial token name.
Fields to match
An EMT record should allow you to compare:
- Issuer’s legal name and, where shown, LEI.
- Token commercial name and currency reference.
- Link or reference to the published white paper.
- Start date for the offer or admission to trading.
- Other crypto-asset services listed for the entity.
- Date of the credit-institution or EMI authorisation.
- Any withdrawal, precautionary measure or other status notation.
Copy the record’s wording and date into your evidence log. If the register provides multiple versions, identify which one was current on the day of your check and retain older versions for comparison.
What the register does not prove
ESMA’s interim register expressly warns that the crypto-asset white papers listed there have not been reviewed or approved by a competent authority in any EU Member State. A listing demonstrates that a document was notified or published in the register; it is not a supervisory endorsement of reserves, solvency, redemption performance or marketing statements.
The register also cannot cure an identity mismatch. A similarly named issuer, an old corporate entity or a token with a different currency reference is not a match. Ask why a record is absent before assuming non-compliance: the offer may not have started, the filing may be under a different legal name, or a transition may apply. Do not convert uncertainty into a “compliant” conclusion.
Withdrawals and historical evidence
Withdrawals of an ART, EMT or CASP authorisation remain published in the MiCA register for five years. A current search can therefore show a historical withdrawal. Record whether the entry is active, withdrawn or subject to a public measure, and record the date. An old withdrawn entry is not evidence of present authorisation.
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Step 4: verify the underlying credit or e-money licence
The Article 48 authorisation test
MiCA Article 48 requires that a person must not offer an EMT to the public or seek its admission to trading in the Union unless that person is the issuer, is authorised as a credit institution or electronic money institution, and has notified and published a crypto-asset white paper in accordance with Article 51.
That is a two-part check: the correct regulated entity must hold the financial-sector authorisation, and the token documentation must satisfy the MiCA filing requirement. A CASP authorisation, payment-service registration, money-transmitter licence or exchange listing alone does not meet the issuer test.
Use the competent authority’s national register
Follow the competent-authority reference in the ESMA record or white paper to the relevant national register. Search the exact legal issuer name and verify:
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- Authorisation type: credit institution or EMI.
- Licence number and legal entity identifier.
- Status: active, suspended, withdrawn or otherwise limited.
- Authorisation date and any effective restrictions.
- Whether the authorised entity is the same company named as the EMT issuer.
National registers may use local-language corporate names or separate lists for banks and EMIs. Search the licence number and registered address as well as the English name. A current “authorised” result should be dated in your notes; a screenshot without a date is weak evidence.
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An authorised institution may provide services across the Union, but the passport does not change which legal entity issued the token or which authority granted its licence. Confirm the issuer’s home Member State and the scope of the authorisation. If a group advertises EU-wide availability while the token documents name a different, unauthorised subsidiary, pause the assessment.
Step 5: read and reconcile the current white paper
Identity and classification
Check that the white paper’s issuer name, LEI, registered address, token name, ticker and euro reference exactly match the ESMA and national-register records. Note the document version, publication date and any replacement or amendment notice.
Rights and redemption language
Locate the sections describing holder rights, redemption, claims against the issuer, fees, insolvency treatment and any limits. For an EMT, the document should identify the relevant issuer and explain the token’s relationship to the referenced official currency. Do not treat a general promise to “maintain a peg” as a legal redemption right unless the document states the right and its conditions.
Authority and responsibility statements
Record the named competent authority and the document’s statement about regulatory status. A white paper can disclose risks and obligations without being approved by that authority. Preserve the current document and any archived version so that a material change in rights or issuer identity is visible.
Step 6: check dates, transition claims and public measures
Application date
ESMA and the European Commission identify 30 June 2024 as the start of application for MiCA Titles III and IV, which cover ART and EMT activities, subject to the stated transitional provisions. A token launched before that date may have a transition statement, but a transition claim is not a permanent exemption. Read the applicable Member State notice and the issuer’s current disclosure.
Forty-working-day notification
Article 48 requires an EMT issuer to notify its competent authority at least 40 working days before the intended public offer or admission to trading. The period is a notification deadline, not a guarantee that the authority approved the token or its reserves. Compare the intended offer date with the register’s offer or admission start date and note any later amendment.
Public warnings and precautionary measures
Search the ESMA entry and the competent authority’s notices for withdrawals, suspensions or precautionary measures. A warning may concern the issuer, a specific token or a service. Record its scope and date rather than describing every notice as a finding that the token is illegal.
How to compare two euro stablecoin issuers
Use the same fields for each issuer. A side-by-side record prevents a stronger-looking marketing page from substituting for evidence.
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| Comparison field | Issuer A | Issuer B | What to establish |
|---|---|---|---|
| Legal issuer and LEI | Record exact register wording | Record exact register wording | Names and identifiers match the white papers |
| MiCA category | EMT, ART or unresolved | EMT, ART or unresolved | Single-euro reference normally points to EMT; baskets require ART analysis |
| Underlying authorisation | Credit institution or EMI; date | Credit institution or EMI; date | Current national-register status and scope |
| ESMA register status | Active, withdrawn or measure; date | Active, withdrawn or measure; date | Article 109 record matches the legal entity and token |
| White-paper version | Version and publication date | Version and publication date | Current document agrees with register identity and rights |
| Offer or admission date | Register date | Register date | Consistent with the 40-working-day notification timeline |
| Redemption and reserve disclosures | Quote section and conditions | Quote section and conditions | Do not infer rights from a price peg alone |
| Home Member State and authority | State and authority | State and authority | National licence search reaches the named authority |
| Significant-token supervision | Applicable, not stated or unclear | Applicable, not stated or unclear | Additional supervision does not replace issuer authorisation |
Where a fact is not displayed, write “not stated” and identify the register or document checked. Never fill an empty cell with an assumption.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Keep an auditable verification file
A short evidence file makes the conclusion reproducible. Include:
- Date and time of each search, with the relevant time zone.
- Exact ESMA record title, status and offer or admission date.
- National register result, licence number, authorisation type and status.
- White-paper file name, version, publication date and a stable local copy.
- Issuer, LEI, token name and currency-reference comparison.
- Any withdrawal, precautionary measure, transition statement or unresolved discrepancy.
- The person or team who performed the check and the conclusion reached.
Use a conclusion label that reflects the evidence: verified on the checked date, not verified, or inconclusive—escalated. “Verified” should mean only that the identity, authorisation, register and document checks agree at that point in time; it is not a prediction about price stability or credit risk.
Common traps and how to fix them
The exchange is regulated, so the token must be compliant
Why it fails: the exchange may be a CASP while the issuer is a separate company. Fix: identify the issuer in the white paper and verify its credit-institution or EMI licence.
The white paper appears in ESMA’s register, so ESMA approved it
Why it fails: ESMA says listed white papers have not been reviewed or approved by a Member State competent authority. Fix: treat the listing as filing evidence and perform the national-licence check separately.
A one-to-one price proves EMT status and compliance
Why it fails: market price does not determine legal classification, and a peg does not establish redemption rights. Fix: read the reference-asset definition and rights section in the current white paper.
A parent company’s banking licence covers every subsidiary
Why it fails: authorisation attaches to the named legal entity. Fix: match the issuer’s exact corporate name, LEI and licence number; investigate any subsidiary or trading-name mismatch.
An old register entry is treated as current
Why it fails: withdrawals remain visible for five years and historical records can look like active records. Fix: read the status and date fields, then confirm the current national-register result.
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The issuer invokes a transition without identifying its scope
Why it fails: transitional treatment can depend on the Member State, activity and dates. Fix: require a dated statement that identifies the applicable provision and verify the present authorisation path.
Significant-token supervision is mistaken for a licence
Why it fails: an EMT or ART may involve European Banking Authority supervision when it meets significance criteria, but that does not remove the underlying authorisation requirement. Fix: check the issuer’s credit-institution or EMI authorisation first, then record any additional supervisory status.
Official legal wording that controls the check
MiCA Article 48 states: “A person shall not make an offer to the public or seek the admission to trading of an e-money token, within the Union, unless that person is the issuer of such e-money token and: (a) is authorised as a credit institution or as an electronic money institution; and (b) has notified a crypto-asset white paper to the competent authority and has published that crypto-asset white paper in accordance with Article 51.”
The same article provides: “An e-money token that references an official currency of a Member State shall be deemed to be offered to the public in the Union.” This is why a euro reference triggers the EMT analysis even when the issuer describes the product as a general-purpose stablecoin.
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1Clear out junk files and repair common Windows errors2Fix the driver behind crashes, sound loss and screen glitches3Repair Windows errors before they cause bigger problemsFor comparison, MiCA Article 16 says of the relevant ART authorisation: “The authorisation granted by the competent authority to a person referred to in paragraph 1, first subparagraph, point (a), shall be valid for the entire Union.” That language belongs to the ART route and should not be used to bypass the EMT licence test.
Article 109 requires ESMA to establish a register of crypto-asset white papers, issuers of ARTs, issuers of EMTs and CASPs. Its register function is transparency; it does not turn a listed white paper into a supervisory approval.
A hypothetical verification walkthrough
Suppose a token called “Euro Example” appears on an exchange. Its marketing page names “Example Payments Group,” while the white paper names “Example Payments EMI S.A.” The issuer record should begin with the latter legal name, its LEI and its stated Member State.
- Read the white paper to confirm that the token references one official currency—the euro—and classify it provisionally as an EMT.
- Search the ESMA EMT register for “Example Payments EMI S.A.” and the token name. Record the white-paper version, offer or admission date, authorisation date and status.
- Follow the named authority to the national register. Confirm that the same legal entity holds an active EMI or credit-institution authorisation.
- Compare the register and white paper for the issuer name, LEI, token name, redemption terms and competent authority.
- If the national register lists “Example Payments Group” but not the S.A. issuer, mark the result inconclusive and request clarification. Do not rely on the group relationship or exchange listing.
This process produces a dated, entity-specific conclusion without claiming that the token is risk-free or that a regulator endorsed its commercial model.
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A careful conclusion names the entity and the date: “On the date checked, the issuer named in the current white paper matches the EMT entry in the ESMA register and an active EMI or credit-institution authorisation in the stated Member State. The register and white paper show the recorded offer or admission date, and no withdrawal or precautionary measure was identified in the checked records.”
If any element is missing, say precisely which one: “The token’s exchange listing was confirmed, but the legal issuer could not be matched to an active EMI or credit-institution record.” That is an unverified or inconclusive result, not a finding that the token is authorised. Recheck the registers whenever the issuer changes its legal entity, token terms, white paper or offer venue.
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