Who issues them
Which coins count as e-money tokens in the EU? The answer sits in a spreadsheet. The e-money token file in ESMA’s interim MiCA register, in the update dated November 5, 2026, lists 50 white papers from 25 issuers. Some issuers file one paper per token or per version, and German firm AllUnity alone has six entries, covering euro, Swiss franc, Swedish krona and dollar tokens.
Circle Internet Financial Europe SAS, supervised by France’s ACPR, is listed for USDC and EURC, while Paxos Issuance Europe Oy, supervised in Finland, has four entries, one of them for the dollar token USDG. France is home to six of the 25 issuers, more than any other country. Four issuers are banks, including Banking Circle and Bison Bank, while 20 are electronic money institutions.
Size varies widely. By DefiLlama’s count on November 8, 2026, about 517 million EURC were in circulation, against about 190 million of EURCV, the euro token of Société Générale’s SG-Forge.
What the law gives holders
An e-money token counts as electronic money under Article 48 of MiCA, and Article 49 gives every holder a claim against the issuer. Tokens must be issued at par on receipt of funds and redeemed “at any time and at par value”, with no fee for redemption. Article 50 bans interest, from the issuer and from crypto-asset service providers alike, and counts any reward linked to how long someone holds the token as interest.
Dollar tokens carry one extra limit. Article 58 applies the caps of Article 23 to e-money tokens in a currency that isn’t an EU currency. Suppose a token’s estimated use as a means of exchange in one currency area passes 1 million transactions and €200 million a day, on a quarterly average. The issuer must then stop issuing it and file a plan to bring use back under those levels.
Size can change the supervisor too. On October 14, 2026 the EBA classified USDC as the first significant e-money token among the 45 notified in the EU, so from November 12, 2026 the EBA shares its supervision with France’s ACPR and takes direct responsibility for areas such as own funds and the reserve of assets.
Two misreadings
A white paper in ESMA’s file is not a stamp of approval. On its MiCA page, ESMA says the white papers in its register “have not been reviewed or approved by any competent authority”. What a regulator grants is the issuer’s own authorization as a bank or an electronic money institution.
The second misreading runs the other way. A large coin need not be listed at all, and a search of the November 5 file for Tether, USDT, PayPal and PYUSD returns no rows.
In a statement of January 17, 2025, ESMA told national regulators that trading platforms should stop offering tokens that would qualify as e-money tokens but whose issuer is not authorized in the EU by the end of the first quarter of 2025, while “mere custody and transfer” of them should remain possible.
Outside the EU
The term is European. US law, through the GENIUS Act of July 18, 2025, regulates “payment stablecoins”, and Britain’s 2026 cryptoasset regulations use “qualifying stablecoin” for a regime the FCA expects to start on October 25, 2027.
To check a token, open the e-money token file on ESMA’s MiCA page and search for the issuer’s legal name, which can differ from the brand on the coin. A business deciding which coins to accept as payment in the EU can run the same search on its processor’s shortlist.