Statements made by the European Commission to the press in October 2025 signal that it does not seem to share the major concerns that were expressed by the European Central Bank (ECB) and the European Systemic Risk Board (ESRB) against EU and third-country related stablecoin multi-issuance schemes (SMIS) under the EU's market rules for crypto-assets in Regulation (EU) 2023/1114 (MiCAR). 

However, the final treatment of SMIS under MiCAR is still not clear and potential market participants relying on such schemes should carefully monitor the developments.

Background 

SMIS generally refer to joint issuances of stablecoins that involve an EU-based issuer that works together with one or several non-EU issuers (often within the same group). The jointly issued stablecoins share the same technical characteristics and are presented as interchangeable by the issuers. 

In practice, such stablecoins are usually pegged to an official currency (predominantly the US dollar) and qualify as e-money tokens (EMTs) under MiCAR. Pursuant to MiCAR, the issuance of asset referencing stablecoins, and, in particular, EMTs is subject to specific prudential requirements that ensure investor protection. EU issuers must, in particular:

• redeem the token at par value, any time, without a fee;
• back the token by an asset reserve (composed of high-quality liquid assets); and
• comply with own funds requirements.

In 2024, the French financial supervisory authority (Autorité de contrôle prudentiel et de résolution - ACPR), asked EU authorities to clarify whether such schemes were admissible under MiCAR (Q&A 2024_7068). 

While this question remains to be reviewed, in 2025 the ECB and the ESRB published severe warnings relating to SMIS, pointing out financial stability concerns and indicating that these schemes should not be admissible under MiCAR, or should at least be subject to stricter supervision and enforcement under (amended) MiCAR rules. The key concern is that the EU issuer and the non-EU issuer would be jointly liable for the reimbursement of all issued stablecoins while the EU entity would not be able to cover all redemption requests from EU and non-EU holders with its assets. The ECB and ESRB highlight the following risks that they see as crucial:

• high incentive for non-EU stablecoin holders to demand redemption from the EU entity;
• run on EU issuers of EMTs in stress episodes due to more favorable redemption rules;
• contagion risk across EU banks due to redemption related liquidity strains.

And now?

The European Commission finds itself under pressure by stablecoin issuers, and competent authorities like the ACPR, to provide soon clarification on the treatment of SMIS under MiCAR.  

While the statements of the European Commission towards the press carefully indicate that it does not seem to be willing to follow the suggestion to prohibit SMIS under MiCAR, it is also not entirely clear what the European Commission will suggest to address the risks stemming from SMIS under MiCAR's rules.

Therefore, market participants should expect further guidance and clarifications to come. In particular, entities that aim to access the European market on the basis of a SMIS should closely monitor the developments and align with regulators in their chosen home Member State in order to prepare and time their market access.