MiCA Review: Why the EU Is Rewriting Its Stablecoin Rules Already
The EU reopened MiCA weeks after it took full effect. What the review covers, the fight over non-EU issuers and multi-issuance, and what actually changes for businesses paid in stablecoins.
The MiCA review is the European Commission's formal reassessment of its own crypto rulebook, opened on May 20, 2026, with consultation responses due September 30 and a report to the European Parliament and Council due by June 30, 2027. The timing is the story. MiCA's last transition periods expired on July 1, 2026, so the regulation reached full effect and was reopened for revision in the same season. Two questions dominate: whether stablecoin issuers based outside the EU get any legal route into the bloc, and whether a token issued in two jurisdictions is allowed to stay one token.
We explained the MiCA rules as they stand earlier in this series. This is what Brussels is arguing about next, why American law is driving a European debate, and which parts of your setup this actually touches before 2028.
What the MiCA review actually is
MiCA carries its own review clause, so this was always on the calendar. What wasn't scheduled was how much would end up in scope.
The Commission opened a targeted consultation on May 20, 2026, aimed at issuers, crypto-asset service providers, national supervisors, and central banks. On June 29 it pushed the response deadline back from August 31 to September 30, 2026. After that, the Commission owes Parliament and the Council a report by June 30, 2027, and it may attach a legislative proposal. That proposal is what the industry has already nicknamed MiCA 2.
The consultation runs wider than stablecoins. It asks where the boundary should sit between MiCA and traditional financial services law, how to classify tokenised fund interests and wrapped assets, whether unauthorised providers are still reaching EU users after grandfathering ended, and how to treat DeFi, staking, prediction markets, and tokenised deposits. But the stablecoin chapter is where the institutions have publicly split, so that's where a revision is most likely to bite.
MiCA has no door for non-EU issuers
Here is the gap the review was reported in August to be targeting. MiCA contains no equivalence mechanism at all. There is no procedure by which the EU examines a foreign regulator's stablecoin regime, finds it comparable, and lets issuers supervised under it serve European customers. Every issuer wanting to offer a stablecoin in the EU must stand up an EU credit institution or e-money institution and comply with MiCA in full, regardless of what it already complies with at home.
Some issuers did exactly that. Circle became the first global issuer authorised under MiCA, through its French entity in 2024, and now issues USDC and EURC in Europe. Paxos took the same route through a Finnish entity. Tether never applied, which is why USDT left regulated European venues: Binance restricted it in March 2025, and Revolut is completing its delisting for European users on August 31, 2026.
For excluding an issuer that won't submit to supervision, the design works. The problem is that it treats every foreign regime as if it doesn't exist. A US issuer fully licensed under the GENIUS Act gets no credit for it in Brussels, and an EU business gets no supervised access to coins that dominate global settlement. The consultation asks directly whether an equivalence regime for third-country stablecoin issuers should be introduced. Even the European Central Bank, which opposes the looser options, conceded that a tightly drawn equivalence framework is the only version worth considering.
The fight comes down to one word: fungible
The technical dispute has a plain-English core. Under a multi-issuance model, the same stablecoin is issued by more than one legal entity in different jurisdictions, reserves are split between them, and the tokens remain interchangeable. A holder cannot tell which entity minted the coin in their wallet, and doesn't need to, because one is exactly as good as the other.
That's not a hypothetical structure. It's how the largest MiCA-compliant coins already operate. Circle issues USDC in the United States and separately through France; the tokens are fungible. If Brussels rules that the EU-issued and US-issued versions are legally distinct, the most-used compliant stablecoin in Europe fragments into two assets that happen to share a ticker.
European institutions do not agree on the answer:
| Institution | Position |
|---|---|
| ESRB (recommendation of Sept 25, 2025) | The Commission should establish that MiCA does not permit multi-issuance |
| ECB (non-paper of April 10, 2026) | Third-country multi-issuance should not be allowed; at most a highly restrictive equivalence regime |
| European Commission | MiCA does not prohibit multi-issuer models; existing tools are adequate, and the question belongs in the review |
| European Parliament (vote of July 9, 2026) | 390 to 86 in favour of multi-issuance with safeguards, rejecting the ban |
The ECB's objection is a run scenario. If holders anywhere in the world can redeem through any issuing entity, they will redeem where the protections are strongest, which is the EU. The European entity holds only its share of the reserves, so a global redemption wave lands on a local balance sheet that was never sized for it. The ECB's Financial Stability Review put the same warning in blunter terms: not enough reserve assets sit under EU supervision to meet combined redemption requests.
The counter-argument from Parliament and from industry is that fungibility is the product. A dollar coin that stops being interchangeable across borders stops being useful for cross-border settlement, which is most of what businesses use it for. Circle's Patrick Hansen argued the review "does not signal MiCA's failure," and on the numbers he has a point: roughly 21 authorised issuers and about 35 authorised tokens now operate in the EU. But the market wants the door widened, not the frame declared perfect.
Most analysts expect multi-issuance to survive with conditions attached: obligations to rebalance reserves between entities, redemption gates that restrict where EU customers may redeem, and equivalence tests applied to third-country supervisors.
Why Washington is driving Brussels
The EU review is partly a response to American law. The GENIUS Act, signed in July 2025, settled the US framework in a single summer and included its own comparability route for foreign issuers. That creates reciprocal leverage: a US issuer that wants fungible tokens in Europe needs its home regime recognised in Brussels, and the mirror-image requirement already exists in Washington. Neither side can finish its rulebook without the other.
The competitive pressure is not subtle. Roughly 99% of stablecoin supply is dollar-denominated, stablecoin transaction volume rose about 72% in 2025 to some €28 trillion, and the scale gap inside Europe is stark: USDC alone circulates around $77 billion, while every euro stablecoin combined sits near €674 million, even after triple-digit growth. We covered the euro coin market and the banks entering it separately.
This is also why the ECB's position isn't purely prudential. Executive Board member Piero Cipollone has warned that dollar stablecoins could take hold in European retail payments, and the ECB is building the alternative: a digital euro pilot targeted for mid-2027, with first issuance possible in 2029. An EU diplomat quoted in July put the conclusion plainly, saying reopening the file looks unavoidable given both the institutional positions and worldwide regulatory developments.
Too strict and too late at the same time
The market's complaint about MiCA is unusual because it runs in both directions at once.
Too strict. At least 30% of reserves must sit in commercial bank deposits, which earn less and carry bank risk. Remuneration is banned outright, so euro e-money tokens are structurally non-yielding even when the reserves behind them generate income, a competitiveness problem the consultation document itself raises. The asset-referenced token regime has produced approximately zero licensed tokens. And there is no equivalence route, as above.
Too late. MiCA was drafted before today's stablecoin and tokenisation markets existed. Tokenised deposits and tokenised payment instruments, which EU officials expect to grow quickly, fall outside the perimeter entirely. Even on an efficient timetable, the fix arrives around 2028.
Both criticisms can be true, and both are in the consultation. The awkward part for Brussels is that the consultation implicitly concedes the perimeter was drawn too early, while the framework it questions only finished phasing in six weeks ago.
Nothing binding changes before 2028
The dates are worth keeping straight, because headlines about a MiCA rewrite compress a slow process:
- September 30, 2026: consultation responses close.
- By June 30, 2027: the Commission reports to Parliament and the Council, with a legislative proposal attached if it decides one is warranted.
- 2027 to 2028: any proposal goes through the ordinary legislative procedure, meaning Parliament and Council negotiate the text.
- Around 2028 at the earliest: amendments apply.
Until then MiCA applies exactly as written. Anyone planning on the assumption that the rules are about to loosen is planning for 2028, not for this quarter.
What this means if you get paid in stablecoins
Change nothing today. USDC for dollars and an authorised euro token for euros remain the answer for EU counterparties, and will through the entire review.
Don't wait for USDT to return. Even the most permissive outcome requires an equivalence finding, a recognised home regime, and Tether choosing to opt in. Our USDT and USDC comparison covers where each coin actually works now.
Watch the redemption question, not the headline. If multi-issuance survives with safeguards, the likely form is a rule about where a European holder may redeem. That's a treasury detail for anyone holding large stablecoin balances across jurisdictions. It changes nothing about invoicing a client in USDC.
The fiat boundary stays where compliance concentrates. Whatever the review decides about issuers, the licensed, KYC'd step is still the off-ramp between the token and a bank account. That's the part of your setup worth choosing carefully.
The bottom line
The MiCA review is what happens when a rulebook written before the stablecoin market matured runs into issuers who live outside it. The unresolved question is whether Europe accepts globally fungible tokens under conditions, as Parliament voted, or insists that a coin issued in the EU be legally its own thing, as the ECB and ESRB argue. That answer lands in 2027 and takes effect around 2028. For a business getting paid in stablecoins today, the practical guidance is unchanged from our regulation guide: hold authorised coins, use licensed infrastructure, and treat the token as a settlement rail rather than a place to park money.
FAQ
What is the MiCA review? It's the European Commission's scheduled reassessment of the Markets in Crypto-Assets Regulation. A targeted consultation opened on May 20, 2026 and closes September 30, 2026, and the Commission must report to the European Parliament and Council by June 30, 2027, optionally with a legislative proposal attached.
Is MiCA being replaced by MiCA 2? Not yet, and possibly not at all. "MiCA 2" is industry shorthand for the amending legislation the Commission may propose alongside its 2027 report. No text exists today, and any amendment would still need to pass Parliament and the Council before applying, realistically around 2028.
What is stablecoin multi-issuance? An arrangement where the same stablecoin is issued by more than one entity in different jurisdictions, with reserves split between them and the tokens fully interchangeable. USDC works this way, issued by Circle in the US and separately through its French entity. Whether MiCA permits it for non-EU entities is the central dispute in the review.
Can non-EU stablecoin issuers operate in the EU? Only by establishing an EU credit institution or e-money institution and complying with MiCA in full. There is no equivalence regime recognising foreign supervision, which is precisely what the consultation is asking whether to create.
Will USDT come back to EU exchanges after the review? There's no basis for expecting it. USDT left regulated EU venues because Tether never sought authorisation, and Revolut completes its delisting on August 31, 2026. A return would require an equivalence regime that doesn't exist yet, a US recognition decision, and Tether choosing to participate.
When will new MiCA rules take effect? Around 2028 at the earliest. The consultation closes in September 2026, the Commission reports by June 2027, and any legislative proposal then goes through negotiation between Parliament and the Council. MiCA as currently written stays fully in force throughout.
Does the MiCA review change anything for my business right now? No. The rules in force are the ones described in our MiCA guide: authorised issuers only, full backing, free redemption at par, no interest. Invoice EU counterparties in authorised coins like USDC, and revisit the question when the Commission's 2027 report lands.