The license behind most euro and dollar tokens
Who is allowed to put a dollar or euro token on the EU market? Usually a company with an electronic money license, the status also used for prepaid cards, and often one granted years before MiCA’s token rules applied.
ESMA’s e-money token file, read on November 10, 2026, names 25 issuers. One column states whether each is a credit institution or an electronic money institution, and 20 are the latter. Those 20 account for 44 of the file’s 50 white papers. Four banks file five more, and the last row, for a Luxembourg firm, reads N/A in that column.
Most licenses predate the token rules. Twelve of the 20 institutions carry an authorization date before June 30, 2024, when the e-money token rules of MiCA began to apply.
The oldest is Payment Corporation SE in Prague, authorized by the Czech National Bank on April 26, 2017. Stablecoin issuer Circle’s French entity is dated July 1, 2024. The latest date in that column, June 20, 2026, belongs to Germany’s AllUnity, a year to the day after the date the same file gives for its first white paper, while one Dutch issuer’s row has no date at all.
What the license allows in the EU
The legal basis is a 2009 law, the E-Money Directive. As the directive defines it, electronic money is stored monetary value that represents a claim on the issuer, issued when funds are received and used to make payments.
The directive sets a floor of €350,000 in initial capital. Article 6 bars an EMI from taking deposits from the public, and Article 7 makes it safeguard the money it receives for e-money. Article 12 bans interest or any other benefit tied to how long someone holds the balance.
MiCA builds on that. Article 48 lets a firm offer an e-money token only if it is authorized as a credit institution or as an electronic money institution. Article 54 adds that at least 30% of the funds received for tokens must sit in separate accounts at banks, with the rest in secure, low-risk assets in the same currency.
The UK version
Britain kept the model in its Electronic Money Regulations 2011, which define two types. An authorized EMI must hold at least €350,000 of initial capital under Schedule 2. A small one is capped, since regulation 13 allows average outstanding e-money of no more than €5 million at registration.
The FCA calls them AEMIs and SEMIs. Its safeguarding page says firms protect customer money either by keeping it apart from their own funds or by covering it with an insurance policy or a comparable guarantee, and report on it to the FCA every month.
A balance is not a deposit
The common mistake is to treat money in an e-money app like money in a bank. The UK’s compensation scheme answers that in its FAQ, saying e-money “is considered a method of payment and not a deposit” and that e-money providers “aren’t protected by FSCS.”
Safeguarding is the substitute. If a protected bank holding an EMI’s safeguarded funds fails, the FSCS says it may be able to pay compensation for those funds.
Before you keep a large balance with any EMI, ask which of the two safeguarding methods it uses, and for a token, look up the issuer’s legal name in ESMA’s file to see which license stands behind it.