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E-money token (EMT)

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"E-money token" is the legal name the EU gives to what most people call a fiat-backed stablecoin tied to a single currency. The definition sits in Article 3(1)(7) of MiCA, and the rules in Title IV, which has applied since 30 June 2024.

How an e-money token works

The issuer receives money, for example euros, and issues tokens of the same value on a blockchain. MiCA sets out the core obligations:

  • Who may issue. Only a credit institution or an electronic money institution may offer an e-money token to the public or seek its admission to trading, and it must first notify and publish a crypto-asset white paper (Article 48).
  • Legal status. E-money tokens are deemed to be electronic money (Article 48(2)).
  • Issuance and redemption. Tokens are issued at par on receipt of funds. The holder has a claim on the issuer, which must redeem at any time, at par and in money other than e-money. Redemption carries no fee (Article 49).
  • No interest. Neither the issuer nor a service provider may pay interest (Article 50).
  • Safeguarding. At least 30% of the funds received must be deposited in separate accounts at credit institutions, and the rest invested in secure, highly liquid assets in the same currency (Article 54).

Examples on the ESMA register include USDC and EURC, both issued by Circle's French e-money institution.

E-money tokens and Bulgaria

Bulgaria's Markets in Crypto-Assets Act (ЗПКА), in force since 8 July 2025, gives the Financial Supervision Commission (КФН) oversight of crypto-asset service providers. Supervision of e-money token issuers based in Bulgaria goes to the Bulgarian National Bank. An issuer authorised in another member state, such as Circle's institution in France, is supervised by its home authority.

In January 2025 ESMA asked national supervisors to make sure service providers stop offering stablecoins that do not meet MiCA by the end of the first quarter of 2025. Custody and transfer of such tokens, the statement added, should remain possible.

Example

You hold 10,000 USDC. If you were a Circle Mint customer, Circle would redeem them for USD 10,000 with no redemption fee, as Article 49 requires. As an individual you normally sell through an intermediary instead. At xChange.bg, a technology provider whose accounts and conversions come from the regulated partner Bridge (a Stripe company), the off-ramp fee is 1.25%, so 125 USDC, and the remaining 9,875 USDC is paid out to your bank account in USD, or in EUR at the exchange rate at that moment. The fee is the intermediary's price for its service, not a redemption charge by the issuer.

Common confusion

  • Not every stablecoin is an e-money token. A token that references a basket of currencies or gold is an asset-referenced token, with its own set of rules.
  • "MiCA-compliant" describes the issuer and the white paper. It says nothing about the safety of the blockchain network or your wallet.
  • An e-money token is not the digital euro. It is issued by a private institution, not by a central bank.

Frequently asked questions

What is the difference between an e-money token and an asset-referenced token?

An e-money token references a single official currency. An asset-referenced token (ART) references another value or right, or a mix, which can include several currencies, commodities or crypto-assets. The two have separate authorisation, reserve and redemption rules under MiCA.

Is an e-money token covered by deposit guarantees?

No. MiCA treats an e-money token as electronic money, not as a bank deposit. In Bulgaria the Deposit Insurance Fund covers deposits at banks, and that protection does not extend to stablecoins.

Who supervises e-money token issuers in Bulgaria?

The Bulgarian National Bank supervises e-money token issuers based in Bulgaria. The Financial Supervision Commission supervises crypto-asset service providers under the Markets in Crypto-Assets Act, in force since 8 July 2025.

Can an e-money token pay interest?

No. Article 50 of MiCA forbids issuers and crypto-asset service providers from granting interest on e-money tokens, including any benefit linked to how long the holder keeps the token.

How do I check whether a stablecoin is an authorised e-money token?

Look it up in ESMA's interim MiCA register, which publishes the white papers of e-money tokens together with the issuer, its home supervisor and the notification date. USDC and EURC appear there under Circle Internet Financial Europe SAS.

Sources

  1. Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA)
  2. ESMA interim MiCA register: e-money token white papers (EMTWP.csv)
  3. ESMA public statement on non-MiCA-compliant ARTs and EMTs (17 January 2025)
  4. State Gazette: Markets in Crypto-Assets Act (ZPKA), issue 54 of 4 July 2025

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