
Only 9 of 23 EU stablecoin issuers can custody client tokens. Circle and Société Générale-Forge benefit while the rest wait months for CASP approval.
Fourteen of the roughly 23 stablecoin issuers authorized under the European Union's Markets in Crypto-Assets regulation, known as MiCA, cannot hold their own tokens in custody for corporate clients.
The interim register of the European Securities and Markets Authority (ESMA) lists roughly 23 authorized e-money token issuers. Nine of them hold authorization for both electronic money token (EMT) issuance and crypto-asset service provider (CASP) services. The other 14 hold the issuance side alone. Patrick Hansen, Circle's director of EU strategy and policy, called the position a regulatory gap that severely limits the services they can offer.
MiCA treats issuance and custody as separate authorization categories, so an EMT approval carries no CASP rights with it. The EMT side authorizes a token pegged to a single currency. The CASP side covers custody of client tokens and payment processing on their behalf. An issuer with only the EMT half can create the token. Holding it for clients is a separate authorization, and the 14 do not have it.
Retail users are not affected; they can move tokens freely between non-custodial wallets. The restriction hits the corporate segment. An issuer without a CASP license cannot custody tokens or process automated payments for corporate clients.
Closing the gap runs through the notification procedure under Article 60 of MiCA. In France and Luxembourg, that process can take up to a year. The timeline varies by member state. Several issuers did not wait out the clock. They migrated to regulated third-party platforms, turning custody into a B2B partnership.
Schuman Financial, issuer of the French stablecoin EURØP, is the clearest case. It holds EMT status without CASP authorization, so it uses Ripple's European MiCA CASP and EMI licenses for legal custody and transfers across 30 European countries. EURØP is integrated into the XRP Ledger as part of the arrangement.
The third-party route keeps an issuer's product alive. Completing the Article 60 notification removes the need for it. The register is an interim list, so the count of 14 is not fixed; every approval moves one name into the nine. A longer wait keeps the rest dependent on third-party custodians and pushes more institutional flow toward the two firms that already hold both licenses. The imbalance has no immediate resolution in sight.
Circle, issuer of USDC and EURC, and Société Générale-Forge come out of the split as the main beneficiaries. Both hold the dual authorization the rest of the market will take months, or up to a year, to assemble. The pairing gives both firms a structural advantage in the competition for institutional capital within the European Economic Area. For a corporate client, the choice narrows to nine fully licensed issuers or a partially licensed issuer that runs custody through a third party. The first option limits the field; the second adds a licensed intermediary to the chain.
"Most EU stablecoin issuers can't custody their own token on behalf of customers," Hansen wrote on X on Aug. 13. He said competitors had been passive in the face of the restriction. His employer, Circle, sits on the authorized side of the same register.
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