Stablecoin Reporting Obligations: MiCAR E-Money Tokens and the PSD3 Shift

ByOfficer

Last updated: June 2026

A euro stablecoin looks like a payments product and behaves like one. The reporting file behind it does not. The moment an issuer puts a fiat-referenced token into circulation in the EU, it sits inside banking or e-money authorisation, and for many tokens it also picks up a quarterly supervisory return and a hard cap that can force it to stop issuing. Get the stablecoin reporting obligations wrong and the problem is not a late filing. It is a token that a competent authority can order out of circulation while you rebuild the data pipeline.

This is the part of the stablecoin story that the market commentary skips. Most euro stablecoins in the EU are e-money tokens, and an e-money token is, by law, electronic money with a reporting wrapper bolted on top. The issuer is a regulated entity before it is a crypto project. It files like a bank or like an electronic money institution, and then it files again under the crypto-asset rules. The two regimes do not always line up neatly, which is where reporting teams lose time.

The structural shift that supervisors keep flagging is simple to state. If a token settles payments at scale and holds reserves against redemption, it starts to substitute for bank deposits and for the rails that move them. That is why the rulebook treats a large stablecoin as a financial-stability object, not a wallet feature. And it is why the reporting obligations are built to let central banks watch the volume in near real time.

Related reading: our guide to MiCAR reporting obligations.

Why a stablecoin is a reporting object, not just a token

Under the Markets in Crypto-Assets Regulation, Regulation (EU) 2023/1114, a stablecoin is never a single legal category. It is either an e-money token or an asset-referenced token, and the line between them decides which return you file. An e-money token, or EMT, references a single official currency. An asset-referenced token, or ART, references a basket, a commodity, or anything that is not one single currency. A token pegged one-to-one to the euro is an EMT. A token pegged to a basket of currencies is an ART.

That classification is not cosmetic. MiCAR deems an e-money token to be electronic money as defined in the Electronic Money Directive, Directive 2009/110/EC. The issuer therefore carries the e-money rulebook and the MiCAR crypto rulebook at the same time. An ART issuer, by contrast, lives under a standalone MiCAR authorisation with its own reserve and own-funds regime. Two tokens that look identical to a user can produce two very different reporting calendars.

MiCAR entered into force on 29 June 2023 and applies in general from 30 December 2024. The Titles that matter most for stablecoin issuers, Title III on asset-referenced tokens and Title IV on e-money tokens, started to apply earlier, from 30 June 2024. So the issuance and reporting obligations for ARTs and EMTs have been live since mid-2024, ahead of the rest of the regime. If you are scoping a token now, you are not waiting for the rules. You are already inside them.

One avoidable error is to treat token classification as a one-time legal memo and move on. Classification drives the entire reporting design. If you misread a euro EMT as an ART, you build the wrong authorisation file and the wrong reserve reporting, and you discover it when the competent authority asks why you are not filing as an electronic money institution. We cover the classification mechanics in more depth in our MiCAR token classification guide.

The two doors into issuance: credit institution or electronic money institution

MiCAR does not let just anyone issue an e-money token. Recital 66 and Title IV of Regulation (EU) 2023/1114 require that an EMT be issued either by a credit institution authorised under the Capital Requirements Directive, Directive 2013/36/EU, or by an electronic money institution authorised under Directive 2009/110/EC. There is no third door. A crypto-asset service provider licence, the CASP authorisation that lets a firm run an exchange or custody business, does not authorise it to issue an EMT.

This matters for the reporting baseline. An electronic money institution that issues a euro stablecoin is already a supervised entity with an own-funds position, a safeguarding regime, and a relationship with a national competent authority such as the CSSF in Luxembourg, BaFin in Germany, or the relevant supervisor in the issuer’s home Member State. The EMT obligations sit on top of that existing return, not instead of it.

When I map an EMT issuer’s reporting calendar, the first line is not the MiCAR transaction return at all. It is the e-money own-funds and safeguarding reporting the entity already owes as an electronic money institution. The MiCAR-specific filing is the newer layer, and it is the one most issuers underweight because it has no direct PSD2 ancestor.

The common mistake here is assuming the white paper is the heavy lift. The crypto-asset white paper is a one-off notification to the competent authority before publication, and yes, it has its own data schema. But the white paper is a point-in-time document. The reporting obligation is recurring, quarterly, and tied to live transaction data. Teams that staff the white paper and then under-resource the quarterly pipeline are the ones that miss reference dates later.

Article 22 quarterly reporting: what an in-scope stablecoin issuer files

The core supervisory return for large stablecoins is built on Article 22 of MiCAR. Article 22 is written for asset-referenced tokens, and Article 58(3) extends it to e-money tokens denominated in a currency that is not an official currency of a Member State. So a euro EMT issued in the EU and a dollar-referenced EMT issued in the EU are not in the same reporting position. The dollar EMT, denominated in a non-EU currency, inherits the full Article 22 transaction-reporting machinery through Article 58(3). The euro EMT does not. Article 22 and the Article 23 issuance cap reach e-money tokens only when they are denominated in a non-EU currency, so a euro-pegged EMT files its white paper and its e-money prudential returns but not the Article 22 quarterly transaction report.

Under Article 22(1), the issuer reports to the competent authority, on a quarterly basis, four things: the number of holders; the value of the token issued and the size of the reserve of assets; the average number and average aggregate value of transactions per day during the quarter; and an estimate of the average number and average aggregate value of transactions per day that are associated with uses of the token as a means of exchange within a single currency area.

The reporting is not universal. Article 22(1) applies for each token with an issue value above EUR 100 million. Below that, Article 22(2) lets the competent authority require the same reporting at its discretion. So a smaller issuer is not automatically out of scope. It is out of scope until its supervisor decides otherwise, which is a different and weaker form of relief than an exemption.

The reporting reference dates are fixed at 31 March, 30 June, 30 September and 31 December, following the calendar quarter. The EBA was mandated under Article 22(7) to develop implementing technical standards setting the forms, formats and templates, submitted to the Commission by 30 June 2024. So the structure of the return is standardised, not left to each issuer to design. If you have filed COREP or FINREP, the model is familiar: a defined template, fixed reference dates, and a competent authority that shares the data upward. We set out the prudential template logic in our FINREP reporting explainer.

One operational detail worth flagging: Article 22(4) requires the competent authority to share what it receives with the European Central Bank and, where relevant, the home central bank. Your quarterly EMT return is not a private supervisory conversation. It feeds the ECB’s own view of how much your token is being used for payments, which connects directly to the issuance cap discussed below.

The means-of-exchange estimate and the EBA RTS methodology

The hardest field on the Article 22 return is the means-of-exchange estimate. This is the figure that tells the supervisor how much your token is actually used to pay for goods and services within a single currency area, as opposed to being parked, traded, or moved between an issuer and a service provider. The EBA built a dedicated methodology for it. Commission Delegated Regulation (EU) 2025/298, which adopted the EBA’s draft (EBA/RTS/2024/13) and was published in the Official Journal on 13 February 2025, sets the methodology. It specifies how to estimate the quarterly average number and aggregate value of transactions per day associated with use as a means of exchange under Article 22(6), and applies equally to EMTs denominated in a non-EU currency through Article 58(3).

The methodology works by subtraction. The issuer starts from the total transactions in the token over the quarter and deducts the transactions that do not count as means-of-exchange use. The RTS excludes transactions where the token is exchanged for funds or other crypto-assets with the issuer or a crypto-asset service provider, transactions where the token is used as collateral for trades in financial instruments, transactions used to settle a derivative contract, and other transactions the issuer can reasonably show were not for paying for goods or services.

The geographical scope is narrow on purpose. The RTS counts a transaction only where both the payer and the payee are located in the same single currency area, with location defined as habitual residence for individuals and registered office for legal persons. That single-currency-area framing is what links the estimate to monetary sovereignty: the supervisor wants to know how much euro-area payment activity a private token is carrying.

Here is where teams underestimate the build. The RTS deliberately excludes transactions between non-custodial wallets from the reportable scope, because the issuer cannot reliably see them. That sounds like relief. It is not. The data you do have to capture comes through crypto-asset service providers under Article 22(3), and the RTS requires you to reconcile the data those providers send against the transactional data on the distributed ledger and from other sources. The reconciliation step is the one I flag first in any scoping session, because it is an integration problem, not a reporting-template problem. You are stitching together third-party CASP feeds and on-chain data, then defending the result to a supervisor.

What the rule does not mean: it does not mean the issuer reports raw on-chain volume. Raw volume overstates means-of-exchange use badly, because it sweeps in exchange flows, collateral, and internal transfers. An issuer that files raw volume will trip the issuance cap on paper long before it would in reality. The whole point of the RTS subtraction method is to stop that false positive.

The issuance cap that can stop your stablecoin

The reason the means-of-exchange estimate carries so much weight is Article 23 of MiCAR. Where the estimated quarterly average rises above one million transactions per day and EUR 200 million per day, both thresholds together, the issuer must stop issuing the token and, within 40 working days of reaching that threshold, submit a plan to the competent authority to bring the figure back below the limit. Through Article 58(3), the same restriction applies to e-money tokens denominated in a non-EU currency. A euro-denominated EMT does not face this cap, because Article 23, like Article 22, reaches e-money tokens only through the non-EU-currency trigger in Article 58(3).

Read that again from a reporting officer’s chair. The figure you self-report on the Article 22 return is the figure that can trigger a forced halt to issuance. Article 23(2) lets the competent authority use the issuer’s number, its own estimate, or the ECB’s estimate, whichever is higher, to decide whether the threshold is met. You do not get to rely only on your own lower number. The supervisor can substitute a higher one from the central bank and act on it.

This is the mechanism behind the phrase “structural shift in banking.” A private token that moves more than EUR 200 million of euro-area payments a day, sustained, is competing with the regulated payment and deposit system at scale. The cap is the supervisor’s brake. For an issuer, the practical consequence is that the data quality of your means-of-exchange estimate is not a compliance nicety. It is the difference between staying in the market and submitting a remediation plan under a 40-working-day clock.

It is tempting, and wrong, to treat the cap as a problem only for the very largest issuers. The threshold is per token and assessed on a single-currency-area basis, and Article 23(3) requires the competent authority to aggregate data across issuers where several issue the same token. A token issued by more than one entity is measured as one. An issuer that models its own volume in isolation can be surprised by an aggregated number it never tracked.

Where e-money rules still bite: own funds, safeguarding, and no interest

MiCAR did not switch off the Electronic Money Directive for EMT issuers. Because an e-money token is electronic money, the issuer that is an electronic money institution still carries the prudential spine of Directive 2009/110/EC. That means initial capital of at least EUR 350 000 under Article 4, and an own-funds floor under Article 5 calculated, for the e-money issuance activity, under Method D at 2 percent of average outstanding electronic money. These are not crypto-specific numbers. They are the e-money numbers the entity already lives with, and they continue to apply to the stablecoin.

Three further points change the reporting picture for larger tokens. First, MiCAR bars issuers from granting interest to holders of e-money tokens, including any benefit tied to how long a holder keeps the token. An EMT is a payment instrument, not a savings product, and the reporting cannot smuggle in a yield. Second, where the funds received in exchange for the token are invested, MiCAR requires them to be held in assets denominated in the same official currency the token references, to avoid cross-currency risk in the reserve. Third, an EMT can be designated significant, and a significant EMT issued by an electronic money institution picks up additional requirements, including higher own funds and reserve, custody and liquidity obligations that mirror the asset-referenced token regime rather than the lighter e-money regime.

This is the layered reality of stablecoin reporting that the headline misses. A significant EMT issuer is filing e-money own-funds returns, the heavier reserve and liquidity reporting that significance pulls in, and, where the token is denominated in a non-EU currency, the Article 22 quarterly transaction return through Article 58(3). The EBA set out its expectations for issuers across these tests, and we summarised them in our note on the EBA statement for ART and EMT issuers.

A frequent misread is assuming the e-money safeguarding return and the MiCAR reserve reporting are the same exercise with two labels. They overlap, but they answer different supervisory questions. The safeguarding return protects holder funds in an insolvency. The MiCAR reserve and transaction reporting feeds financial-stability and monetary-policy monitoring. Map them as one and you will misstate one of them.

PSD3 and the PSR: the regime EMT issuers will report into next

The second half of the structural shift is the payments rulebook itself. On 28 June 2023 the European Commission published its payment services package: a proposal for a third Payment Services Directive, PSD3, under reference COM(2023) 366, and a proposal for a Payment Services Regulation, the PSR, under COM(2023) 367. The package reshapes how payment institutions and electronic money institutions are authorised and supervised, and it pulls the e-money regime into the payments regime rather than keeping Directive 2009/110/EC as a separate track.

For stablecoin issuers, the central change is structural. PSD3 is designed to merge the electronic money institution and payment institution frameworks, so that issuing electronic money becomes a category of payment service rather than a separate licence under its own directive. An entity that today holds an electronic money institution authorisation and issues a euro EMT would, under the new regime, sit inside a single payments authorisation with revised own-funds, safeguarding and reporting expectations. The MiCAR obligations do not disappear. The base licence underneath them shifts.

Status matters, and this is where reporting teams need to be precise. As of June 2026, PSD3 and the PSR are not yet in force. EU legislators reached a provisional political agreement on the texts in late November 2025, and the institutions moved through the formal steps in the first half of 2026, with Official Journal publication expected later in 2026. The PSR, as a regulation, would be directly applicable without national transposition, but its provisions would apply only after a transitional period of around 18 months following entry into force, not immediately on publication. PSD3, as a directive, would require national transposition, with applicability expected toward 2028.

The trap is obvious once stated and still common: drafting a target operating model against PSD3 as if it were live law. It is not. The current legal baseline for an EMT issuer remains PSD2 and the Electronic Money Directive, plus MiCAR. PSD3 and the PSR are advanced proposals, not obligations, and the detail can still move in legal-linguistic review. Build for the transition, but report against the rules that are actually in force. We track the moving parts for payment and e-money firms in our PSD3 briefing for payment institutions and electronic money issuers, and the current obligations in our PSD2 reporting requirements guide.

The structural shift, read from the reporting desk

Put the pieces together and the supervisory logic is consistent. A euro stablecoin substitutes for a bank deposit and for the payment rails that move it. So the rules give central banks a quarterly window into how much payment volume a private token carries, through the Article 22 means-of-exchange estimate. They give supervisors a brake, through the Article 23 issuance cap. They keep the issuer inside banking or e-money authorisation, through Title IV and Directive 2009/110/EC. And they line up a payments regime, PSD3 and the PSR, that will absorb the e-money licence into a single payments framework. None of this is crypto exceptionalism. It is the payment and deposit system extending its reporting perimeter to cover a new instrument that behaves like money.

For a reporting officer, the takeaway is that a stablecoin programme needs three plans on day one: the e-money or banking prudential return it already owes, the MiCAR Article 22 quarterly pipeline with a defensible means-of-exchange estimate where the token is in scope (an asset-referenced token, or an EMT in a non-EU currency), and a watching brief on PSD3 transposition. Treat any one of them as optional and the others will not save you.

Frequently Asked Questions

Is a euro stablecoin an e-money token or an asset-referenced token under MiCAR?

A token that references a single official currency, such as the euro at one-to-one, is an e-money token under Regulation (EU) 2023/1114. A token that references a basket of currencies, a commodity, or a mix of assets is an asset-referenced token. The classification decides which authorisation and which reporting regime applies, so it should be settled before any other reporting design work.

Who can issue an e-money token in the EU?

Under Title IV of MiCAR, an e-money token may be issued only by a credit institution authorised under Directive 2013/36/EU or by an electronic money institution authorised under Directive 2009/110/EC. A crypto-asset service provider authorisation does not permit EMT issuance. The issuer is a supervised entity before it is a token project.

What does the Article 22 quarterly return contain?

Article 22(1) requires the issuer to report quarterly to the competent authority the number of holders, the value of the token issued and the size of the reserve, the average number and value of transactions per day, and an estimate of transactions per day associated with use as a means of exchange within a single currency area. Reference dates follow the calendar quarter at 31 March, 30 June, 30 September and 31 December.

Do all stablecoin issuers have to file the Article 22 report?

The reporting applies for each token with an issue value above EUR 100 million. For tokens below that value, Article 22(2) allows the competent authority to require the same reporting at its discretion. A smaller issuer is not automatically exempt, only out of scope until its supervisor decides otherwise. The regime is also currency-gated: Article 22 reaches asset-referenced tokens and EMTs denominated in a non-EU currency through Article 58(3), but not euro-denominated EMTs, which file their white paper and e-money prudential returns instead.

What is the means-of-exchange estimate and why is it sensitive?

It is the estimated daily payment use of the token within a single currency area, calculated under Commission Delegated Regulation (EU) 2025/298 (the adopted RTS based on EBA/RTS/2024/13) by subtracting exchange, collateral, derivative-settlement and other non-payment transactions from total volume. It is sensitive because it feeds the Article 23 issuance cap. If the estimated daily average exceeds one million transactions and EUR 200 million, the issuer must stop issuing and submit a plan within 40 working days.

Is PSD3 in force, and does it replace MiCAR for stablecoins?

As of June 2026, PSD3 and the Payment Services Regulation are advanced proposals, not yet in force. Legislators reached a provisional political agreement in late 2025, with Official Journal publication expected later in 2026 and PSD3 transposition extending toward 2028. PSD3 reshapes the payment and e-money licensing framework that sits underneath an EMT issuer. It does not replace the MiCAR token-specific obligations.

Can a competent authority overrule the issuer’s own transaction figure?

Yes. Under Article 23(2), the competent authority may use the issuer’s number, its own estimate, or the ECB’s estimate, whichever is higher, to assess whether the issuance threshold has been reached. The issuer cannot rely solely on a lower self-reported figure. Where several issuers issue the same token, Article 23(3) requires the data to be aggregated across them.

Related Articles

Key Takeaways

  • Most euro stablecoins in the EU are e-money tokens under MiCAR, which means they are electronic money under Directive 2009/110/EC with crypto reporting layered on top.
  • An EMT can be issued only by a credit institution or an electronic money institution. A CASP licence does not authorise issuance.
  • Article 22 of MiCAR requires quarterly reporting of holders, token value, reserve size and transaction volumes, at reference dates of 31 March, 30 June, 30 September and 31 December, for tokens above EUR 100 million.
  • Article 22 and the Article 23 issuance cap reach asset-referenced tokens and EMTs denominated in a non-EU currency through Article 58(3); a euro-denominated EMT files its white paper and e-money returns but not the Article 22 transaction report. The means-of-exchange estimate follows Commission Delegated Regulation (EU) 2025/298, the adopted RTS based on EBA/RTS/2024/13.
  • The Article 23 issuance cap forces an issuer to stop issuing and file a plan within 40 working days if daily use exceeds one million transactions and EUR 200 million; the supervisor can use the higher of its own, the ECB’s, or the issuer’s figure.
  • Electronic Money Directive rules still apply: EUR 350 000 initial capital, the Method D 2 percent own-funds floor, no interest to holders, and same-currency investment of reserve funds.
  • PSD3 and the PSR are advanced proposals as of June 2026, not in force; they will reshape the payment and e-money licence beneath EMT issuers but do not replace MiCAR token obligations.
  • Build for three returns at once: the e-money or banking prudential filing, the MiCAR Article 22 pipeline, and a transition plan for PSD3.

Sources and References

  • Regulation (EU) 2023/1114 (Markets in Crypto-Assets, MiCAR), Articles 22, 23, 58 and Title IV: EUR-Lex CELEX 32023R1114
  • Directive 2009/110/EC (Electronic Money Directive), Articles 2, 4 and 5: EUR-Lex CELEX 32009L0110
  • Commission Delegated Regulation (EU) 2025/298 supplementing MiCAR with RTS on the methodology to estimate transactions associated with uses of ARTs and EMTs denominated in a non-EU currency as a means of exchange under Articles 22(6) and 58(3) (Commission adoption 31 October 2024; published in OJ 13 February 2025): EUR-Lex CELEX 32025R0298. Originating EBA work: EBA/RTS/2024/13 (19 June 2024): EBA Final Report (PDF)
  • ESMA MiCA crypto-asset white paper taxonomy (e-money tokens): ESMA
  • Proposal for a Directive on payment services and electronic money services (PSD3), COM(2023) 366, 28 June 2023: European Parliament Legislative Train (PSD3)
  • Proposal for a Regulation on payment services in the internal market (PSR), COM(2023) 367, 28 June 2023: European Parliament Legislative Train (PSR)
  • European Commission payment services package landing page: EC Finance, Payment services

What to put on the stablecoin reporting calendar now

If you are scoping a euro or dollar EMT today, the rules are already in force and the calendar is already running. Pin the three reference points before anything else: the e-money or banking prudential return the issuer owes regardless of the token, the MiCAR Article 22 quarterly return with a means-of-exchange estimate you can reconcile and defend (for an asset-referenced token, or an e-money token in a non-EU currency), and the EUR 100 million issue-value trigger that pulls the return into mandatory scope. Then add the watch items: the Article 23 cap that can stop issuance, and the PSD3 and PSR proposals that will redraw the licence underneath you before this decade is out. A stablecoin is a payments product to the user. To the reporting desk it is three regimes filed in parallel, and the order you build them in decides whether the launch holds.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.

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