
14 of 23 EU stablecoin issuers lack CASP licenses, blocking custody of their own tokens for corporate clients. Circle and Société Générale-Forge gain an early institutional edge. Article 60 compliance takes up to a year.
More than half of Europe's authorized stablecoin issuers cannot hold their own tokens in custody for clients, a regulatory gap that hands Circle and Société Générale-Forge an early lead in the institutional market.
Of roughly 23 issuers registered under MiCA's electronic money token (EMT) framework, only nine have also obtained a CASP license – the separate authorization needed to provide custody and process automated payouts on behalf of corporate customers, according to ESMA's interim register.
The other 14 are stuck. They can issue tokens, but they cannot manage them for the businesses that want to use them.
"Most stablecoin issuers in the EU cannot provide custody of their own tokens on behalf of clients. This severely limits the range of services they can offer," said Patrick Hansen, Circle's head of EU strategy and policy. He said he was surprised by how few competitors had prepared for the requirement.
Retail holders face no restriction: they can still transfer tokens between non-custodial wallets freely. The trap is in the B2B segment. Without a CASP license, an issuer cannot hold tokens in custody or run automated payouts for corporate clients.
To get that license, companies must notify regulators under Article 60 of MiCA – a process that can take up to a year in large jurisdictions like France or Luxembourg, Hansen said.
Rather than wait, some issuers have started outsourcing to third-party regulated platforms, creating a period of forced B2B alliances.
Schuman Financial, the French issuer of the EURØP stablecoin, holds EMT status but lacks CASP authorization. The project integrated its asset into the XRP Ledger infrastructure and now relies on Ripple's European MiCA licenses – both CASP and EMI – to provide legal custody and transfers across 30 European countries.
Market participants expect the imbalance to persist. Completing the Article 60 notification process in major European jurisdictions takes months to a year, according to industry sources.
That timeline gives Circle, issuer of USDC and EURC, and Société Générale-Forge a durable edge in the competition for institutional capital inside the European Economic Area, until the euro stablecoin sector moves beyond this period of forced alliances and returns to direct product competition.
Circle's Hansen said the regulatory gap is likely to remain a structural feature of the market for at least 12 to 18 months.
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