The European Union is moving toward a review of its Markets in Crypto-Assets regulation, known as MiCA, with potential changes expected in 2027. The focus centers on how the framework treats stablecoins issued by entities outside the bloc, including multi-issuance arrangements where reserves and operations span multiple jurisdictions.

Officials have identified limitations in the current rules, which generally require an authorized EU-based issuer for stablecoins offered to the public or admitted to trading within the Union. Gaps remain around third-country issuers and structures in which parts of issuance or reserves sit outside EU supervision.

Commission Consultation Underway

The European Commission opened a targeted consultation on May 20 directed at industry participants such as crypto-asset service providers and issuers, as well as public authorities including national supervisors, central banks, and finance ministries. The process seeks to determine whether MiCA remains fit for purpose in light of market and regulatory shifts since the rules were finalized.

Responses from the specialized audience are invited until September 30. The exercise forms part of broader assessment requirements under the regulation and could lead to legislative proposals following the review timeline.

Impact of Full MiCA Implementation

MiCA’s transition period ended on July 1, 2026. This development prompted certain major non-EU stablecoin issuers to lose access to regulated trading venues across the European Union. Tether’s USDT, the most widely circulated stablecoin and issued from a base in El Salvador, was among those affected after failing to secure the required authorization.

The situation has underscored challenges for global issuers seeking continued market presence under the existing perimeter. At the same time, the rapid expansion of the stablecoin sector has increased pressure for clearer cross-border rules.

US Developments Add Competitive Context

Advances in the United States have contributed to the timing of the European discussion. The GENIUS Act, enacted in 2025, established a federal framework for dollar-backed stablecoins. US President Donald Trump has publicly supported the asset class, including through an executive order aimed at promoting dollar-denominated stablecoins and limiting central bank digital currencies within US jurisdiction.

Stablecoin activity has expanded significantly. Annual payment volumes reached approximately 390 billion dollars in 2025, according to data cited from McKinsey & Company, compared with less than 30 billion dollars in 2020. Broader forecasts from market participants project total stablecoin supply could grow substantially by 2030, with estimates ranging from 3 trillion to 4 trillion dollars in certain scenarios. The vast majority of existing stablecoins remain denominated in US dollars.

These trends have heightened attention among EU policymakers and member states to the competitive and supervisory implications of foreign-issued tokens circulating in European markets.

Scope of Potential Adjustments

Beyond non-EU issuers, the review is expected to consider technological developments such as tokenization of payments and related instruments. Authorities have noted that multi-issuance models, in which a single token type is supported by both EU and non-EU entities with interchangeable tokens and divided reserves, present particular supervisory questions.

Any eventual changes would follow the Commission’s assessment of consultation feedback and subsequent legislative steps. Outcomes could range from refined access conditions for third-country issuers to strengthened requirements around reserves and operational controls for tokens available in the Union.

The process remains at an early stage, with the consultation providing the immediate channel for stakeholder input before formal decisions on reopening the legislative file.