How the EU handles oversized stablecoins

Two separate mechanisms in the EU’s Markets in Crypto‑Assets (MiCA) regulation come into effect as a stablecoin grows: a designation that increases supervision and a usage ceiling that applies to tokens pegged to currencies other than the euro.

A token becomes ‘‘significant’’ when it meets at least three tests from a list that includes number of holders, issuance value or reserves, average daily transaction count and average daily transaction value, together with qualitative indicators such as connections to the wider financial system and the issuer’s cross‑border activities. A separate trigger exists if an issuer is designated a gatekeeper under the Digital Markets Act.

MiCA separates e‑money tokens (EMTs), which reference a single currency, from asset‑referenced tokens (ARTs), which reference baskets of currencies, commodities or crypto assets. ARTs carry heavier obligations under the rules.

Designation alters supervision and capital obligations. For significant asset‑referenced tokens, the European Banking Authority (EBA) assumes direct EU‑level supervision. For significant e‑money tokens issued by electronic money institutions, supervision is shared: national authorities remain involved while the EBA oversees compliance with the extra requirements for significant EMTs. Article 35 sets a minimum own funds requirement of €350,000 or 2% of average reserve assets, whichever is greater, with higher levels for tokens that are designated significant.

Significant e‑money tokens must hold a larger share of their reserves as deposits in EU banks, increasing those tokens’ exposure to the European banking system as they grow.

The second mechanism applies only to tokens pegged to a non‑euro currency and only to use as a means of payment inside the EU. When payment use within the EU exceeds defined thresholds — reported in secondary analyses at roughly one million transactions per day and about €200 million in daily transaction value measured as quarterly averages — the issuer must stop issuing new tokens and file a remediation plan with its national authority to reduce payment usage below the limit. The cap covers payments for goods and services and does not restrict trading, custody or on‑chain settlement.

The EU designed the payment ceiling to limit the chance that a foreign‑currency stablecoin becomes a dominant retail payment instrument in the euro area. Global stablecoin value is concentrated in dollar‑denominated tokens; the ceiling permits non‑euro tokens to be held and traded in Europe while restricting their use as everyday payment rails.

Public information on formal significance designations is mixed. Reporting in early 2026 indicated the EBA had applied significant status to a small number of tokens by March, with USDC, EURT and EURC named in some accounts, while other analyses reported no formal designations for asset‑referenced tokens in the first quarter. Differences reflect separate legal paths for ARTs and EMTs and uneven public communication of designation decisions.

The MiCA regime remains largely untested. The euro stablecoin market is small, public designations appear limited, and no issuer has publicly triggered the payment ceiling, so enforcement under stress has not been observed.

U.S. proposals take a different approach: obligations scale with issuer size and include a threshold that moves oversight from state to federal level, but U.S. rules do not include a usage ceiling that bars wide domestic payment use of a compliant stablecoin.