MiCA introduces new expectations for how Electronic Money Tokens (EMTs) are issued, used, and supported across the EU, reshaping how EMT regulation applies in practice. For some businesses, the challenge is understanding whether the regulation applies to their product.

Part of the confusion comes from language. The word stablecoin can be used broadly. Under MiCA, however, not all stablecoins are treated the same. All EMTs are stablecoins, but not all stablecoins are EMTs. 

MiCA introduced E-Money Tokens (EMTs) as a specific category, which reference a single official currency (like EUR or USD), and are legally classified as electronic money. That classification matters, because EMTs can trigger payment obligations that do not automatically apply to other types of stablecoins. 

March 1st marks a key regulatory milestone. By that date, regulators expect businesses dealing with EMTs to have a clear understanding of how their products operate under MiCA, and whether additional regulatory requirements apply under the EMT regulatory framework.

In practice, this means companies should no longer be assessing EMT use cases in the abstract. By March 1st, businesses are expected to have:

• Mapped how EMTs are used within their product
• Identified whether EMTs are moved on behalf of users
• Determined whether this activity remains within MiCA alone or triggers further obligations

As this deadline approaches, organisations are asking: Does EMT regulation actually affect us and what do regulators expect us to have in place?

Compliance starts with clarity on your product’s EMT use cases, rather than abstract regulatory interpretation. From there, EMT compliance under MiCA often comes down to understanding one simple rule.

‍

The practical guide behind EMT regulation under MiCA

At a high level, regulators focus on what your product actually does with EMTs.

More specifically, the key distinction is this:

• If your product moves EMTs on behalf of users, additional regulatory requirements are triggered.
• If it does not, the regulatory scope is usually more limited.

This distinction helps determine whether your EMT-related activity stays within MiCA alone, or whether additional payment-related obligations come into play.

‍

What does “moving EMTs on behalf of users” mean under EMT regulation?

Moving EMTs is not about internal accounting or technical architecture. It’s about user-facing functionality.

Examples of activities that are typically considered moving EMTs for users include:

• Allowing users to send EMTs to other people or external platforms
• Using EMTs to pay merchants or settle transactions
• Transferring EMTs from one wallet to another at a user’s request

In these cases, the business is actively handling value transfers on behalf of users, which is why regulators apply closer scrutiny.

‍

What usually does not count as moving EMTs

Not all interaction with EMTs involves transfers on behalf of users. For example:

• Buying or selling EMTs on a platform
• Holding EMTs in custody without inbound or outbound transfer functionality
• Using EMTs only within a closed, internal ecosystem

These activities may still fall under MiCA, but they typically do not trigger the same additional expectations as payment-style use cases.

‍

Why the March 1st MiCA deadline matters for EMT compliance

By March 1st, regulators will expect businesses using EMTs to be able to clearly explain:

• How EMTs are used within their product
• Whether EMTs are moved on behalf of users
• How this has been accounted for in the product and compliance setup

This is less about formal paperwork and more about clarity. Uncertainty, assumptions, or unclear boundaries are what create regulatory risk.

‍

How to check if EMT regulation applies to your product

A useful way to sense-check your readiness is to ask:

Can we clearly explain what our product does with EMTs?

If the answer fits in one or two sentences, you are likely on the right track. If it doesn’t, it may be time to take a closer look.

‍

How EMTs are assessed under MiCA and PSD2

For businesses that want a more detailed view of how EMTs sit between MiCA and existing payment rules, and how regulators are approaching this distinction, we explore this in more depth in our whitepaper on the MiCA–PSD2 interplay.

Understanding this interaction early makes it significantly easier to choose the right path forward and avoid last-minute surprises as regulatory expectations take effect.

‍

‍

Disclaimer

The information provided in this article is intended solely for general informational purposes and should not be interpreted as professional advice from Januar. Please be aware that Januar is not a financial advisor. We strongly recommend that individuals seek independent guidance from qualified legal, financial, or accounting professionals before making any cryptocurrency investment decisions.

About Januar

Januar is a leading Payment Institution (PI) and Crypto-Asset Service Provider (CASP) committed to empowering fellow CASPs in navigating the complex regulatory landscape where MiCA and PSD2 intersect. With deep expertise in both digital payment solutions and crypto regulatory compliance, Januar offers comprehensive support to help providers manage the challenges posed by overlapping requirements.

Our team combines regulatory insights with innovative technology to design tailored solutions that streamline compliance processes, ensuring that our partners can focus on their core business while mitigating regulatory risks. Whether it’s managing fiat conversion processes or structuring payment services in line with both MiCA and PSD2, Januar is your trusted partner in achieving robust, compliant financial operations.

Visit Januar.com or write to sales@januar.com to become a customer or learn more
about how Januar can support your business.

‍