E-Money Token Issuer License
Authorization to issue e-money tokens (single-currency stablecoins) under MiCA Title IV, requiring credit institution or EMI authorization, 100% reserve backing, and par-value redemption on demand.
MiCA Title IV, Articles 48-58
Capital Required
€350,000 or 2% of average reserve assets (whichever higher)
Timeline
4-8 months
Fees
€5,000-50,000 (member state dependent)
Regulatory Body
ESMA / National Competent Authorities (NCAs)
Legislative Framework
Markets in Crypto-Assets Regulation (MiCA) 2023/1114, Payment Services Directive 2 (PSD2), Digital Operational Resilience Act (DORA)
Last updated: June 2025
Key Requirements
Maintain minimum capital of €350,000 or 2% of average reserve assets whichever is higher per MiCA Article 50(1).
Obtain authorization from credit institution or electronic money institution per MiCA Article 48(1) prerequisite.
Establish 100% backing of issued e-money tokens with reserve assets held in segregated accounts per MiCA Article 51(2).
Develop published whitepaper detailing token economics, reserve composition, issuance/redemption procedures per MiCA Article 53.
Implement robust governance structure with separate treasury and risk management for reserve assets.
Establish redemption procedures guaranteeing par-value redemption on demand without conditions per MiCA Article 52(3).
Maintain quarterly reserve asset audits by independent auditors with public quarterly attestation reports.
Implement anti-money laundering procedures and transaction monitoring for all token issuance and redemption activities.
Application Process
Secure authorization as credit institution or EMI with relevant NCA or banking supervisor.
Prepare comprehensive whitepaper including reserve composition, redemption procedures, governance structure, and risk management framework.
Establish segregated reserve accounts with verified custody arrangements and independent audit procedures.
Submit application to NCA including whitepaper, governance documents, compliance framework, and proof of prerequisite authorizations.
Engage with NCA through assessment period for clarifications on reserve management and operational procedures.
Obtain NCA approval and publish whitepaper, then register token issuance with relevant blockchain platforms.
Establish reserve account funding and implement token issuance infrastructure under NCA supervision.
Expected Total Timeline
4-8 months
Ongoing Obligations
After obtaining your E-Money Token Issuer License, these are the continuing compliance requirements you must maintain.
Maintain 100% reserve backing at all times with monthly reconciliation and quarterly independent audit attestations.
Publish quarterly reserve composition reports within 30 days of quarter end detailing reserve assets, distribution, and custodial arrangements.
Monitor and report token circulation volume to NCA quarterly with any significant market movements or redemption pressures.
Maintain redemption procedures ensuring par-value redemption within 5 business days per published terms.
Conduct annual independent audits of reserve assets and issue public audit reports confirming 100% backing compliance.
Notify NCA of any material changes to reserve composition, custody arrangements, or redemption procedures within 15 days.
Maintain governance records including management meeting minutes, reserve management decisions, and risk assessments available for NCA review.
Cost Summary
Capital Requirement
€350,000 or 2% of average reserve assets (whichever higher)
Application & Licensing Fees
€5,000-50,000 (member state dependent)
Jurisdiction Setup Cost
$40,000-$120,000
Annual: $50,000-$150,000
Other European Union (MiCA) Licenses
Explore other license types available in European Union (MiCA).
CASP Authorization
Asset-Referenced Token Issuer License
CASP -Custody & Administration
CASP -Trading Platform Operation
Need help with E-Money Token Issuer License?
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