MiCA Stablecoin Rules Reshape EU Liquidity, 100 Days On

One hundred days after MiCA's grandfathering deadline closed the EU's regulatory on-ramp for crypto firms, the new MiCA stablecoin rules have done more to reshape euro liquidity than any market rally. Euro-pegged stablecoin supply has climbed 22.6% this year to $848.1 million, while the dollar segment sits flat, according to Token Terminal data cited in a new report from Finery Markets. The institutional read is blunt: compliant euro issuance is taking share inside a market that has otherwise stopped growing.

The report, published to mark 100 days since the 1 July 2026 deadline, draws on commentary from a MiCA-compliant stablecoin issuer, a dual-licensed payment institution, and a regulated custodian. Together their accounts describe a market where the headline authorisation is only the first of several permits a firm now needs to move euros on-chain.

What actually changed at the 1 July deadline?

The 1 July 2026 date closed the transitional window under Article 143(3) of MiCA, the clause that let firms providing crypto-asset services under old national regimes keep trading while they applied for a full Crypto-Asset Service Provider (CASP) authorisation. It was the outer EU-wide limit rather than a single shared cut-off: several member states set earlier application deadlines, and firms that missed their national date lost grandfathered cover first.

The conversion rate has been thin. Of the 1,200-plus entities holding pre-MiCA national registrations across the bloc, only around 210 had secured full CASP authorisation by mid-2026, a conversion of roughly 17%, according to the ESMA interim register. For the firms left outside, the options narrowed to authorisation, an orderly wind-down, a transfer of clients to a licensed provider, or exit.

Why is euro stablecoin supply rising while the dollar stalls?

The growth is supply-led rather than demand-led. Euro-denominated stablecoin supply rose from $691.7 million on 1 January to $848.1 million by 7 September, a net addition of about $156 million. Dollar-pegged tokens added almost exactly the same absolute amount, roughly $159 million, but from a base near $298.5 billion, leaving dollar growth at a negligible 0.05%. Euro stablecoins still account for just 0.3% of global stablecoin supply against the dollar's 99.5%.

That makes the euro's advance a currency-share shift inside a stationary market, with the overall category size broadly unchanged. The supply is also highly concentrated: Circle's EURC holds about 62.6% of euro stablecoin supply and Société Générale's EURCV a further 19.6%, so two issuers control roughly 82% of the segment. Ethereum hosts 69.4% of euro stablecoin value and Solana 14.7%, with the two chains absorbing nearly all of the year's growth.

Finery Markets' own platform data points the same way. EURC volume on its venue grew 46 times year on year across the first nine months of 2026, the firm says, making euro-pegged stablecoins its fastest-growing segment. Yet EUR-denominated trading on the platform, which includes dollar stablecoins traded against the euro, grew 24% year on year, slower than its over-the-counter volume as a whole. Euro liquidity, in other words, is still routed mainly through dollar stablecoins. These platform figures are self-reported and specific to Finery's order flow rather than the wider market.

What is the "double test" problem for bank issuers?

Banking Circle, the Luxembourg payments bank that issued EURI, the first bank-backed MiCA-compliant stablecoin, in August 2024, argues that the way reserve rules bite on credit institutions is holding issuance back. Under MiCA, e-money token issuers must hold a large share of reserves as cash deposits at banks while avoiding over-concentration at any single institution. The European Banking Authority applies two separate tests to credit institutions, which together cap how much an issuer can place with one bank.

Banking Circle's position is that this double test should not apply where reserves sit in a bankruptcy-remote structure with ring-fenced and readily available liquidity, the model it uses for EURI's segregated reserves. The argument matters because a handful of large banking relationships underpins almost every compliant euro issuer, and tighter concentration limits raise the operational cost of scaling supply. This is the issuer's interpretation of the rules rather than a settled supervisory position.

How are firms that missed the deadline staying in the market?

Many did not leave. Fipto, which describes itself as Europe's first dual-licensed stablecoin payment institution, holding both a MiCA CASP licence from France's AMF and a payment institution licence from the ACPR, reports that firms which missed the 1 July authorisation deadline have largely stayed active by partnering with a licensed CASP. Under that structure the licensed partner contracts directly with the end client and carries the regulatory responsibility, while the unauthorised firm supplies technology or distribution behind it.

Fipto secured its ACPR payment institution licence in March 2025 and its AMF CASP authorisation in January 2026, the combination it says lets a single entity own the full payment chain across fiat and stablecoins. The partnership route keeps capacity in the market, but it also concentrates regulatory liability on the small number of firms that cleared authorisation on time.

Does a MiCA licence cover everything?

No, and that is the point a regulated custodian raised in the report. A MiCA permit alone does not cover every activity needed to run a complete payment service. Certain transfers of e-money tokens on behalf of clients also fall within the scope of the EU's second Payment Services Directive, or PSD2, creating overlapping authorisation requirements.

That overlap is not a drafting quirk. In a no-action letter published on 10 June 2025, the EBA confirmed that because MiCA deems e-money tokens to be electronic money, they carry a dual nature as both crypto-assets and funds. Custodial wallets that let clients send and receive token transfers are therefore treated as payment accounts, and the transfers themselves can require authorisation as a payment institution or e-money institution on top of the CASP licence. National regulators were advised to allow a transition period to 1 March 2026 for firms needing the additional PSD2 permit, and own-funds requirements can apply cumulatively: a custody-and-transfer CASP faces €125,000 of initial capital under MiCA plus a separate PSD2 requirement. For custodians and payment firms, the practical result is a stacked permit set rather than a single licence.

Why This Matters to FinanceX Readers

For treasury teams, payment firms, and the investors backing them, the first 100 days of MiCA confirm that the cost of moving euros on-chain is now a compliance question before it is a liquidity one. The regulated euro rail is being built, but it is expensive to sit on: reserve concentration limits, stacked CASP and PSD2 permits, and a two-issuer supply base all raise the bar for anyone trying to scale. The market's growth is coming from issuers minting compliant supply rather than from a surge in end-user demand, which leaves euro liquidity dependent on dollar stablecoins for now. Investors weighing European digital-asset infrastructure should watch which firms hold the full permit stack, because those are the entities the rest of the market will have to route through.