Asset-referenced token

MiCA sorts every stablecoin not pegged to exactly one official currency into this bucket, whether it tracks gold, a currency basket, or a mix. Title III, which governs them, started applying on 30 June 2024, six months before the rest of the regulation. A crypto-asset that does not purport to maintain a stable value against anything is neither one of these nor an e-money token. Recital 18 leaves it in a third type that Title III never reaches.

How it works

Article 3(1)(6) of Regulation (EU) 2023/1114 builds the asset-referenced token category by exclusion: a crypto-asset that is not an electronic 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. Recital 18 explains the width: the type is meant to catch everything backed by assets that is not an e-money token, so as to avoid circumvention and keep the regulation future-proof.

Issuing one in the EU is a licensed activity. Article 16 lets only an issuer established in the Union and authorised by its home Member State's competent authority, or a credit institution following Article 17, offer one to the public or seek its admission to trading; that authorisation then holds across the entire Union. A carve-out in Article 16(2) applies where the 12-month average outstanding value, measured at the end of each calendar day, never exceeds EUR 5,000,000 and the issuer is not linked to a network of other exempt issuers, though a white paper still goes to the home authority.

The prudential floor sits in Article 35: own funds of at least the highest of EUR 350,000, 2% of the average reserve of assets, or a quarter of the previous year's fixed overheads. Article 36 keeps that reserve legally segregated from the issuer's own estate, so its creditors cannot reach it in an insolvency, and Article 39 gives holders a permanent right of redemption that, under Article 39(3), carries no fee.

Article 23 caps how popular an asset-referenced token is allowed to become: once its estimated quarterly average use as a means of exchange inside a single currency area passes 1 million transactions and EUR 200,000,000 per day, the issuer must stop issuing and, within 40 working days, hand the authority a plan to bring both figures back under those lines.

Where you see it

Asset-referenced token is a label a European regulator applies, not a name a project markets itself under, so you meet it in filings rather than on a ticker. Article 30 makes that disclosure public: the issuer has to publish, somewhere easily accessible on its own website, how much of the token is in circulation plus the value and composition of the reserve, updated at least monthly. On this site the term sits behind the licence guides for the covered EU member states and for Norway, which applies MiCA through the EEA.

Asset-referenced token vs Electronic money token

The line between an asset-referenced token and an electronic money token is a count of currencies. Article 3(1)(7) reserves the e-money token label for a crypto-asset tracking the value of one official currency; reference two currencies, or a currency plus gold, and Article 3(1)(6) takes over. What changes is who may issue: Article 48 admits only a credit institution or an authorised electronic money institution, while Article 16 opens issuance to any authorised Union undertaking.

Asset-referenced token vs Stablecoin

Stablecoin is trade vocabulary rather than a legal class. The word appears exactly once in all of Regulation (EU) 2023/1114, in recital 41, in quotation marks, describing so-called algorithmic stablecoins. That recital also shuts the obvious escape route: what a token references decides whether Title III or Title IV applies, irrespective of how its issuer designed the stabilisation mechanism. An algorithmic design aiming at a stable value against one or several assets is regulated as an asset-referenced token or an e-money token whatever its documentation calls it.