Patrick Hansen
Patrick Hansen|Jul 24, 2026 09:00
Equivalence for foreign stablecoins under MiCA in the EU? 🇪🇺 As the debate around how to bring foreign-issued stablecoins (99% of global stablecoins in circulation are primarily issued outside of the EU) into the EU regulatory perimeter is taking place, equivalence is emerging as a compelling alternative to the multi-issuance model, currently the only possible regulatory pathway for these global stablecoins under MiCA. Equivalence frameworks in EU financial services are anything but novel. The EU has long relied on them across a broad range of regulatory frameworks - from Solvency II (where Brazil, Japan, Mexico and the US already benefit from provisional equivalence for insurance) to EMIR (where the UK's CCP framework was again recognised as equivalent in January 2025), to the Benchmarks Regulation, the CRR, MiFID II and beyond. The benefits of equivalence are well established and highlighted on the dedicated EU Commission website (link in comments). Equivalence: ✅ Reduces duplicative compliance burdens for market participants ✅ Can allow non-EU firms to operate in the EU without needing a local establishment ✅ Enables more favourable capital treatment for EU banks ✅ Opens cross-border investment, expansion of EU players and fair trade opportunities Applying this same logic to e-money tokens could let regulators verify that a foreign issuer's home framework delivers equivalent outcomes - without forcing a parallel EU issuance structure. The legal architecture and business precedents already exist. The framework can be tailored as needed, e.g. to require local licensing, a local branch, local capital or liquidity requirements, supervisory collaboration & MoUs etc. The ongoing Markets Integration Package negociations and the upcoming MiCA review are the ideal legislative vehicles to introduce such a practical, long-term solution for foreign stablecoins under MiCA, thereby ensuring that MiCA can capture the majority of the stablecoin market. Link to the chart below in the comments.(Patrick Hansen)
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