Crypto-funded debit card in European Union

MiCA Regulation (EU 2023/1114) (2023) — Comprehensive CASP authorization, token issuance, white paper requirements — fully effective Dec 30, 2024

Transfer of Funds Regulation (recast) (2023) — Travel Rule — EUR 0 threshold (no de minimis)

AMLD6 (2024) — AML/CFT harmonization across EU

VASP: CASP authorization under MiCA via home NCA. 9 service classes: custody (EUR 50K), trading platform (EUR 150K), exchange (EUR 125K), order execution (EUR 50K), placing (EUR 50K), reception/transmission (EUR 50K), advice (EUR 50K), portfolio mgmt (EUR 50K), transfer services (EUR 50K). Prudential: higher of fixed minimum or 1/4 prior year fixed overhead.

EXCHANGE: CASP authorization with EU-wide passporting (notify home NCA, 20 business days). Transition: up to 18 months for existing operators (July 2026 deadline). France chose 6 months, Germany 12 months.

CUSTODY: CASP Class 1 — EUR 50,000 minimum capital. Asset segregation mandatory. Client assets held on trust.

National Competent Authorities — CASP authorization in home member state (AMF, BaFin, CNMV, CBI, etc.)

Issuer Licensing: Only EU-authorized credit institutions or e-money institutions (for EMTs) or approved ART issuers (EU-incorporated) can issue stablecoins. Requires publishing a white paper approved by national competent authorities (NCAs), plus ongoing disclosures and governance meeting European Banking Authority (EBA) standards. Crypto-asset service providers (CASPs) must verify issuer compliance via due diligence.

Redemption Rights: Holders of EMTs have guaranteed redemption at par value without fees. ARTs have similar stabilization mechanisms but stricter reserve rules.

Algorithmic Stablecoins: Effectively banned; MiCA (Article 43) requires all ARTs to maintain reserve assets, prohibiting purely algorithmic or non-collateralized stablecoins from being offered or traded in the EU.

Reserve Requirements: Issuers must maintain 100% backing with high-quality, liquid assets (e.g., same currency as the token for EMTs), held in segregated accounts with reputable custodians. Reserves must match outstanding tokens 1:1, with no interest paid to holders and compliance with existing e-money rules. Limits apply to non-euro stablecoins for payments to protect monetary sovereignty.

Evidence fact eu.tax not found (may have been renamed).

In January 2026, the French Autorité des Marchés Financiers (AMF) became the first NCA to publicly announce a formal enforcement action under MiCA, issuing a cease-and-desist order against an unregistered non-EU CASP (CryptoFlow Ltd., registered in the Cayman Islands) for soliciting French residents without authorization; the AMF noted this action as a "test case" for MiCA enforcement coordination across NCAs AMF MiCA Enforcement Action January 2026

A March 2026 analysis by the European Systemic Risk Board (ESRB) identified that 8 of the 27 EU NCAs had not yet finalized their MiCA enforcement guidelines by Q1 2026, creating "supervisory fragmentation risks" for CASPs operating across multiple member states; the ESRB warned that this could lead to inconsistent application of authorization requirements and investor protections by the April 2026 enforcement date ESRB Analysis of MiCA Supervisory Fragmentation

The European Commission's March 2026 enforcement update confirmed that the Netherlands Authority for the Financial Markets (AFM) had issued formal warnings to 14 crypto-asset firms for failing to submit complete authorization applications by the February 28, 2026 deadline; the AFM warned that firms without approved authorization by April 1, 2026, would face immediate suspension orders European Commission MiCA Enforcement Update March 2026