USDT is not illegal in the EU: the MiCA stablecoin registry

Holding USDT in Europe is not prohibited: what MiCA prohibits is a regulated exchange selling it to you. This sentence summarizes the most widespread misunderstanding regarding stablecoins in the European Union, and it can be verified in a public file that almost no one opens: the register of EMT (e-money token, the MiCA category for stablecoins pegged to a single official currency) issuers that ESMA, the European Securities and Markets Authority, publishes in CSV format and refreshes weekly. In its July 31, 2026 version, it contains 21 issuing entities spread across 12 jurisdictions of the European Economic Area and covers 24.7% of the $308.512 billion that makes up the global stablecoin market today. The remaining 59.3% represented by USDT is not excluded due to a veto from Brussels: it is out because Tether never submitted an application. This article translates that CSV into a readable list —which issuer, which token, which country, which authority, which date, and the weight of each— explains what you can and cannot do with absent stablecoins, and points out who is actually crossing the regulatory threshold while the public conversation remains focused on Tether.

Is it legal to hold USDT in Europe in 2026?

Yes. The confusion stems from mixing three things that MiCA treats separately: issuing, offering, and holding. The regulation governs the first two and says nothing about the third.

The document that draws the line is the public statement issued by ESMA on January 17, 2025 (reference ESMA75-223375936-6099), coordinated with a Q&A from the European Commission. Its instruction to national supervisors was to demand compliance "as soon as possible and no later than the end of the first quarter of 2025." In practice, this meant that trading platforms had to delist any crypto-asset qualifying as an EMT or ART without an authorized issuer in the EU, and that CASPs (crypto-asset service providers, the licensed entity under MiCA) had to stop providing reception and transmission of orders, execution of orders on behalf of clients, and exchange of crypto-assets for funds or other crypto-assets for those tokens, when such services amount to an offer to the public.

The same document sets the limit on the other side with a literal phrase: "the mere custody and transfer of these crypto-assets should remain possible." Added to this was a sell only window —sales only, no new purchases— which extended until the close of the first quarter of 2025 so that European holders could liquidate or convert positions without an abrupt cutoff.

This creates the practical map. An EU resident can hold USDT in their own wallet, move it between chains, receive it as payment, keep it in custody at an authorized CASP, and transfer it out. What they cannot do is buy it on a regulated European exchange or trade USDT pairs on that platform. The EMT register is a list of issuers authorized to offer, not a list of assets permitted for citizens.

It is worth remembering another phrase from the statement, as it dismantles the "Brussels banned Tether" narrative: ESMA acknowledges that neither it nor national authorities "possess any formal power to disapply a directly applicable EU legal text." The delistings were the mechanical consequence of a regulation that had already been in force since June 30, 2024, and the decision of an issuer not to enter it.

Which stablecoins are authorized under MiCA as of July 31, 2026?

ESMA maintains an interim register composed of five CSV files: whitepapers for general crypto-assets, ART issuers, EMT issuers, authorized CASPs, and non-compliant entities. The third one is what matters here. The distinction between EMT (a single reference currency) and ART (a basket of assets) is detailed in our analysis of the MiCA and DAC8 framework; for the purposes of this list, all commonly used stablecoins pegged to the Euro or the Dollar fall into the EMT category.

The file downloaded on August 3, 2026 —whose last modification on the ESMA server is July 31 at 14:45 GMT— contains 41 whitepaper lines corresponding to 21 issuing entities in 12 jurisdictions: Czech Republic, Germany, Denmark, Finland, France, Iceland, Lithuania, Luxembourg, Latvia, Malta, Netherlands, and Poland. Iceland enters via the European Economic Area, not the EU.

Two warnings for reading the file. First: a column in the original ESMA CSV —which this table does not reproduce— records the date of license as an electronic money institution, not the MiCA date; this is why the raw file contains entries from 1979 (CACEIS) or 2007 (Oddo BHF), which are banks with prior licenses. The relevant date to know when a token entered the MiCA perimeter is the whitepaper notification date, which is what the table shows. Second: "n/a" means that DefiLlama does not publish a capitalization series for that token, usually because it circulates below the aggregator's tracking threshold; in rows with multiple tokens, the figures follow the same order as the tokens column.

A detail that the Euro-vs-Dollar debate often overlooks: the register already covers seven reference currencies —Euro, Dollar, Swiss Franc, Swedish Krona, Pound, Polish Zloty, and Romanian Leu. Quantoz notified PLNQ and GBPQ on April 7, 2026, and RONQ on April 15; AllUnity added SEKAU on May 6. The tokenized money infrastructure that MiCA is authorizing looks more like a network of European currencies than a rival to the digital dollar.

How much of the global market does this register actually cover?

Crossing the CSV with the capitalization of each token gives the exact measure of the regulatory reach. Summing the tokens in the register with public series on DefiLlama, the authorized block amounts to $76.215 billion out of a global market of $308.512 billion.

Within that 24.7%, there is a concentration that conditions everything else: USDC represents 94.5% of the authorized block. If USDC were to have a regulatory, operational, or reserve problem, the European legal stablecoin perimeter would drop to around $4.2 billion — just over 1% of the market. Dependence on a single issuer is higher within the EU than outside it.

The second uncomfortable number affects the underlying political project. All Euro-denominated stablecoins in the world, authorized or not, total $863 million: 0.28% of the market. Those authorized under MiCA hover around 815 million. Two years after MiCA became applicable, tokenized Euro still moves less value than the daily volume of many pairs on a mid-sized exchange.

Why did European exchanges delist USDT?

The sequence of delistings is well-known: Coinbase removed USDT for EEA clients in December 2024, Kraken followed in early 2025, Crypto.com moved its European entity to Malta and removed it, and Binance applied geoblocking to USDT pairs for EEA users. Since July 1, 2026, when the transitional regime for CASPs (MiCA-licensed crypto-asset service providers) expired, no platform with a MiCA license offers USDT trading pairs to European retail users.

The cause is not in the token's behavior, but in a business calculation by the issuer. MiCA requires EMT issuers to maintain at least 30% of reserves in demand deposits at credit institutions, a percentage that rises to 60% for EMTs designated as "significant" by the European Banking Authority — a threshold USDT would easily cross based on the number of holders and value in circulation. Paolo Ardoino, CEO of Tether, has maintained in several interviews throughout 2026 that this requirement is incompatible with their model: it would mean moving tens of billions from US Treasury bills to European bank deposits, with lower yields and counterparty risk concentrated in banks that the regulation itself limits to 10% per entity and 30% per banking group. On why the interest margin is the heart of both issuers' business, see our analysis of Circle and Tether's exposure to Fed rates.

Circle took the opposite view and did so early: its French subsidiary appears authorized with a whitepaper notification date of July 1, 2024, the day after the EMT rules became applicable. It was the first issuer in the register alongside Société Générale-Forge, and that head start explains much of the market share it holds in Europe today. For the design contrast between both tokens, we have the comparison of USDC vs USDT and decentralized alternatives.

Who is actually crossing the MiCA threshold?

Of the 21 authorized entities, six are authorized by the French ACPR: Circle, Société Générale-Forge, SALVUS, Oddo BHF, HEURO, and CACEIS Bank. France concentrates nearly 29% of the EMT issuers in the European Economic Area, more than Malta, Luxembourg, and the Netherlands combined.

And except for Circle, all those French entries are banks. Société Générale-Forge is the bank's digital asset subsidiary. Oddo BHF is a Franco-German private bank, which notified its EUROD token on October 15, 2025. CACEIS Bank, the asset services arm of the Crédit Agricole group, notified its whitepaper on June 30, 2026: it is the most recent entry in the entire register, with just over a month of existence. In Germany, AllUnity —the joint venture backed by asset manager DWS, Galaxy, and Flow Traders, authorized by BaFin— has notified three tokens in twelve months. The door that MiCA opened is being crossed by banks, custodians, and asset managers; crypto-native issuers that did enter can be counted on one hand.

The second silent discovery is in Finland. Paxos Issuance Europe Oy, an electronic money institution since November 23, 2022, notified the whitepaper for USDG, the dollar of the Global Dollar Network consortium, on December 19, 2025. With $3.350 billion in circulation, USDG is now the second-largest token in the EMT register, far ahead of any Euro stablecoin, and the only candidate with real size to challenge USDC in the authorized European market.

The bitter side of that same register: authorized banks issue very little. Société Générale-Forge's EURCV has been in circulation for over two years and totals $176 million. Banking Circle's EURI, $44 million. Monerium's EURe, $38 million. AllUnity's EURAU, $1.3 million. Having the license and having demand turn out to be two different problems.

Can a European buy RLUSD, USD1, or PYUSD?

None of the three appear in the EMT register as of July 31, 2026, and the three absences have different origins.

The case of PYUSD illustrates better than any other how the register works: it authorizes specific legal entities and whitepapers, not brands. Paxos is in —via Paxos Issuance Europe Oy in Finland— but what that entity has notified are EUROe, eUSD, and USDG. PayPal's dollar is issued by another group company in the United States and therefore remains outside the European perimeter.

Ripple's case illustrates the other frequent confusion: mixing two licenses that do not overlap. A CASP authorization enables providing services on crypto-assets —custody, executing orders, operating a market—; an EMT authorization enables issuing the token. Ripple has the first in Luxembourg and not the second, as we detailed in the analysis of RLUSD's multi-jurisdictional strategy. The flip side of that coin —which platforms passed the July 1 CASP filter— is in our review of the end of the transitional regime for exchanges.

What about DAI and USDS, which have no issuer to authorize?

Sky's $11.363 billion —$6.563 in USDS and $4.799 in DAI— are the register's blind spot. There is no company to which a supervisor can grant or deny an EMT authorization, because the tokens are issued by a protocol governed by holders of a governance token.

Sky commissioned a legal opinion concluding that MiCA's EMT clauses do not apply to it due to its decentralized structure, and that European platforms can therefore list DAI. It is important to place that document correctly: it is a partisan thesis, not an exemption granted by ESMA or any national authority. The regulatory support it invokes is Recital 22 of MiCA, which leaves out services provided in a "fully decentralized" manner, without offering any test to determine when that condition is met. ESMA has not published Level 3 guidance resolving the point, and advisors involved in drafting the regulation have publicly argued the opposite: that only authorized EMTs and ARTs can be listed, and that the doubt would have to be resolved by European courts.

The result is a limbo that translates into inconsistent decisions: some European platforms keep DAI listed based on that reading, while others have removed it out of caution. For the user, the practical consequence is the same as with USDT —holding and self-custody without issue, variable availability in the regulated market— but with a relevant difference: DAI's status could change abruptly if ESMA publishes its criteria.

And the "limited network" exemption of Article 48?

The CSV includes two columns that almost always read "No": ae_exemption48_4 and ae_exemption48_5. They mark the exemption that MiCA inherits from the electronic money directive for tokens circulating in closed networks or whose average amount in circulation does not exceed 5 million euros over twelve months. Only one entity out of the 21 has it activated: Payment Corporation SE (Stable Labs), authorized by the Czech National Bank, whose own whitepaper states that the token "is not offered to the general public, but is used exclusively within a clearly defined and functionally limited ecosystem." It is a figure designed for tokenized loyalty cards or intra-group settlement. No issuer with open market ambition can use it; for USDT, RLUSD, or USD1, it is not an entry path.

What should be watched in future register updates?

Four things deserve monitoring in the coming weeks. The first is the register's format itself: ESMA announced that the CSV file system would be provisional "until mid-2026," when it would be integrated into its IT systems. As of August 3, 2026, the register remains a downloadable CSV, with the deadline already passed — a minor detail in appearance, but one that affects historical traceability: the file is overwritten every week and there is no published archive of previous versions.

The second is whether the European Banking Authority designates any EMT as "significant," which would raise the bank deposit requirement to 60% and make the business more expensive precisely for the issuer with the most volume in the register. The third is the pending guidance on decentralization: any criteria ESMA publishes regarding Recital 22 will immediately move Sky's $11.363 billion to one side of the line or the other. And the fourth is the MiCA review planned for this year, where the treatment of stablecoins issued outside the EU is one of the open points — a front running parallel to the divergence of the British FCA framework.

For those holding stablecoins in Europe, the operational summary fits in three lines:

• Holding and self-custodying any stablecoin is legal, whether or not its issuer is in the register.
• Buying and selling on a MiCA-licensed platform is only possible with tokens from registered issuers: in practice, USDC and, with increasing availability, USDG.
• If exposure is in an absent token, the exit path is not a future ban but a present liquidity risk: fewer pairs, worse execution, and more dependence on platforms outside the European perimeter.

Sources and links: ESMA — EMT issuer register (CSV, version of July 31, 2026) · ESMA — MiCA page and interim register · ESMA — statement on non-compliant ARTs and EMTs (Jan 17, 2025, PDF) · DefiLlama — stablecoin capitalization · EBA — technical standards on ART and EMT · Ledger Insights — the DAI and Sky controversy under MiCA · Finance Magnates — Binance removes USDT from European spot