European Union Moves Forward With MiCA Review To Address Non-EU Stablecoin Guidelines

The European Union is advancing a formal review of its Markets in Crypto-Assets Regulation (MiCA), with particular attention directed toward rules governing stablecoins issued outside the bloc. Officials view the exercise as necessary to close gaps that have become more visible since the framework entered full application and amid international developments in digital assets.

MiCA created the EU’s first comprehensive, harmonized set of rules for crypto-assets, their issuers and service providers.

Provisions covering asset-referenced tokens and e-money tokens (commonly known as stablecoins) began applying in mid-2024, with the remaining requirements taking effect later that year.

The regulation requires EU-based authorisation for issuers, imposes strict reserve, redemption and disclosure obligations, and aims to protect consumers while supporting innovation within a single market.

However, the current text does not explicitly address multi-issuer arrangements in which the same fungible stablecoin is issued both by an EU-authorised entity and by entities based in third countries.

Nor does it contain an equivalence mechanism that would allow recognition of comparable regulatory regimes elsewhere.

As a result, non-EU issuers that wish to reach European users generally need to establish a local presence and meet MiCA standards in full.

Policymakers have grown concerned that this approach may limit access to global liquidity, create supervisory challenges when reserves are held across jurisdictions, and leave room for regulatory arbitrage.

These issues have gained urgency following the adoption of dedicated stablecoin legislation in other major markets, notably the United States.

Dollar-denominated tokens continue to dominate global volumes, and European institutions, including the European Central Bank, have highlighted potential financial-stability risks arising from cross-border multi-issuance structures.

At the same time, market activity in tokenised deposits and other distributed-ledger-based payment instruments has expanded, areas that fall partly or wholly outside MiCA’s original perimeter.

In response, the European Commission opened public and targeted consultations in May 2026.

Stakeholders were invited to comment on whether the existing rules remain fit for purpose, whether an equivalence regime for third-country stablecoin frameworks should be introduced, how multi-issuer models should be treated, and whether the regulation’s scope should be widened to cover additional activities such as certain forms of decentralised finance, staking, lending and tokenised payments.

The deadline for responses was later extended to the end of September 2026.

Under the terms of MiCA itself, the Commission is required to deliver a review report by mid-2027.

That report may be accompanied by legislative proposals.

Diplomats familiar with the discussions describe a reopening of the file as effectively inevitable, driven both by internal institutional positions and by the need to keep pace with technological and regulatory changes abroad.

Any eventual amendments would still need to navigate the ordinary legislative procedure, meaning new rules would be unlikely to take effect before 2028.

The review therefore represents an opportunity to refine Europe’s approach: preserving strong consumer and financial-stability safeguards while improving interoperability with global markets and ensuring the framework remains competitive. Crypto and blockchain industry participants, supervisors and other interested parties have a clear window in which to shape the next iteration of the rules.