EMT vs ART under MiCA: how tokens are classified

MiCA sorts every crypto-asset into one of three categories, and which one a token lands in decides who authorises it, what it must publish and whether it can be issued at all. The line between the two stablecoin types — EMT and ART — turns on a single question. The register shows how decisively that question has been answered: 23 EMT issuers, and not one asset-referenced token.

Published: August 2026 · Data as of 12 August 2026 · Reading time: ~6 minutes

Key Takeaways

  • MiCA has three buckets: e-money tokens (EMTs), asset-referenced tokens (ARTs), and everything else — "other" crypto-assets, which is where utility tokens sit.
  • The dividing question is simple: does the token track exactly one official currency? If yes, it is an EMT. If it tracks anything else — a basket, gold, a mix — it is an ART.
  • USDC and EURC are EMTs. A gold-backed or basket-pegged token would be an ART.
  • The registers are lopsided: 43 EMT white papers from 23 issuers — Circle, Société Générale-Forge, Paxos, banks — against zero authorised ART issuers, and 960 white papers from 600 offerors in the "other" category.
  • Category decides the regime: ARTs face the heaviest rules (Title III), EMTs sit under Title IV and must be issued by a credit or e-money institution, and "other" tokens only need a Title II white paper.

The three buckets

MiCA does not regulate "crypto" as one thing. It defines a crypto-asset broadly, then splits it three ways, and almost everything about a project's obligations follows from which split it falls into.

CategoryWhat it isMiCA titleOn the register
E-money token (EMT)Tracks one official currencyTitle IV23 issuers
Asset-referenced token (ART)Tracks anything else of valueTitle III0
Other crypto-assetsEverything not stabilising a value — utility tokens, most listed tokensTitle II600 offerors

The dividing line: one currency, or anything else

Both EMTs and ARTs are what the market calls stablecoins. MiCA separates them with one question — what is the token pegged to?

An e-money token is defined as a crypto-asset that purports to maintain a stable value by referencing the value of one official currency. One currency. Nothing else. A euro-pegged token, a dollar-pegged token — these are EMTs.

An asset-referenced token is defined as a crypto-asset that is not an e-money token and that purports to maintain a stable value by referencing another value or right, or a combination of them — including one or more official currencies. That covers a basket of currencies, a commodity like gold, a mixed pool of assets, or a combination.

So the test runs in that order: is it pegged to exactly one official currency? If yes → EMT. If it stabilises value some other way → ART. If it does not try to hold a stable value at all → neither, and it falls into "other".

Two worked examples:

  • USDC references the US dollar alone → EMT. Same for EURC and the euro.
  • A token backed by gold, or by a basket of dollar, euro and yen → ART.

The third bucket is the residual and by far the largest. A governance token, an exchange token, a network utility token — none of them promise a stable value, so they are simply "other crypto-assets" and need only a Title II white paper.

Why the classification matters so much

The category is not a label — it sets the entire regime.

ARTs (Title III) carry the heaviest requirements in MiCA. The issuer needs authorisation as an ART issuer, must maintain a reserve of assets segregated from its own, meet own-funds requirements, publish an approved white paper, and honour a permanent right of redemption. If an ART becomes "significant" by size or reach, supervision moves up to the European Banking Authority.

EMTs (Title IV) are treated as electronic money, and the crucial constraint is who may issue them: only an authorised credit institution or e-money institution. Holders must be able to redeem at par, at any moment, at face value. That single requirement explains the shape of the EMT register — it is populated by banks and licensed payment institutions, not by crypto startups.

Other crypto-assets (Title II) get the lightest treatment: draw up a crypto-asset white paper, notify the national regulator, publish it. No authorisation of the issuer, no reserve, no redemption right.

What the register actually shows

The theory produces a very uneven reality.

EMTs: 43 white papers from 23 issuers. The names are telling — Circle Internet Financial Europe, Société Générale-Forge, Paxos Issuance Europe, AllUnity, CACEIS Bank, Oddo BHF. Banks and regulated payment firms, exactly as Title IV requires. (For the market picture, see our analysis of Europe's regulated stablecoin market.)

ARTs: zero. More than a year and a half into MiCA's application, the asset-referenced token register is empty — the file is published with a header and no rows. Not one issuer has taken on Title III's reserve, own-funds and redemption obligations. We looked at why in the empty ART register.

Other: 960 white papers from 600 offerors. The residual bucket is where nearly all activity lives, because it captures every listed token that does not try to hold a peg.

Read together, the three registers say something blunt about MiCA's design: the heavier the regime, the emptier the register. Title II is crowded, Title IV has a small club of banks, and Title III — the strictest — has no takers at all.

Frequently Asked Questions

What is the difference between an EMT and an ART under MiCA? An e-money token references the value of exactly one official currency. An asset-referenced token references anything else — a basket of currencies, a commodity like gold, or a combination of assets. That single question decides the category.

Is USDC an EMT or an ART? USDC references the US dollar alone, so it is an e-money token (EMT) under MiCA Title IV. A gold-backed or basket-pegged token would be an asset-referenced token instead.

Are utility tokens regulated by MiCA? Yes, but lightly. A utility token does not attempt to maintain a stable value, so it is neither an EMT nor an ART — it falls into "other crypto-assets" and needs only a Title II crypto-asset white paper notified to a national regulator, with no issuer authorisation.

Who can issue an e-money token in the EU? Only an authorised credit institution or electronic money institution. Holders must be able to redeem at par at any time. That is why the EMT register is made up of banks and licensed payment firms.

How many asset-referenced tokens are authorised under MiCA? None. As of 12 August 2026 the ART register is empty — no issuer has been authorised under Title III.

Sources

  • MICA Watch snapshot of the ESMA registers, data as of 12 August 2026. Browse EMT issuers, ART issuers or crypto-asset white papers.
  • Regulation (EU) 2023/1114 (MiCA), Article 3 definitions of "e-money token" and "asset-referenced token"; Title II (other crypto-assets), Title III (ARTs) and Title IV (EMTs). Supervisory context: MiCA regulators and the EU framework.
  • European Banking Authority — asset-referenced and e-money tokens under MiCA, including the significance assessment.