Why it matters
Under the Markets in Crypto-Assets Regulation, which of these two boxes a token falls into decides its redemption right, who may issue it, what its backing must consist of, which authority supervises it, and whether it counts as funds under European payments law. There is no third box for a value-referencing token, and nothing in between.
The register shows what the market did with that choice. ESMA's interim register of notified e-money token white papers carried 46 rows at its stated last-update date of 24 July 2026, corresponding to 20 distinct issuers. Its interim register of asset-referenced token issuers carried a header row and no data rows at all. That is not a gap in the data: it is a real zero, and it is the most informative single fact about how the classification has worked in practice.
How it works
An e-money token references a single official currency. An asset-referenced token references anything else: a basket of currencies, a commodity, another asset or a combination.
The consequences diverge from there. An e-money token may be issued only by a credit institution or an authorised electronic money institution, and it qualifies as funds under the payment services framework. Asset-referenced tokens are excluded from that definition. Holders of an e-money token have a claim to redemption at par value, at any time, and without a redemption fee. Holders of an asset-referenced token are entitled to the market value of the referenced assets, or to delivery of the assets themselves, with the issuer required to disclose the redemption conditions and the valuation method. Neither issuer may grant interest, and the prohibition extends to crypto-asset service providers as well.
Backing rules differ by category and by size. At least 30% of the funds received must be held as deposits in credit institutions; for a significant e-money token the requirement rises to 60%, held across several credit institutions. Significance is triggered by meeting three of six criteria (more than 10 million holders, more than €5bn in value, more than 2.5 million daily transactions, more than €500m in daily volume, activity on an international scale, or interconnectedness with the financial system) and brings supervision by the European Banking Authority and heavier own-funds requirements.
Economic mechanism
The classification is best read as a price list, with each box offering something and charging for it.
The e-money box sells par redemption and payment-instrument status. It charges the deposit requirement and the yield prohibition. An issuer therefore earns the carry on at most 70% of its book, or 40% once the token is designated significant, and lends the remainder unsecured to commercial banks. It may pay its holders nothing, so it cannot compete for balances on price and must instead compete by paying distributors. That is the same rent structure that operates under the American regime, arrived at from a different statute.
Allan Pedersen's SUERF Policy Note of 16 July 2026 names the awkwardness in that bargain: bank-grade prudential machinery applied to issuers with no deposit insurance, no resolution regime and no access to a lender of last resort, whose mandated deposits are themselves uninsured private credit sitting underneath an unconditional promise to pay par. He calls it narrow-bank prudence without the safety net, and argues the regime holds three incompatible objectives at once: a fixed par value, private credit creation through the backing assets, and no public backstop.
The asset-referenced box sells flexibility in what may be referenced and charges the par promise for it. A holder entitled to market value bears the price risk of the reference, which means the token cannot function as a payment instrument and the issuer has no float business, because the return on the assets belongs economically to the holder. Strip out par and strip out the carry, and what remains is a fund or a structured note wearing an unfamiliar authorisation. The incentive is unambiguous, and the empty register is the result: any issuer that can reference a single official currency does so, because par is what makes the instrument useful and the yield prohibition makes it costless to hand the return to nobody.
Participants
National competent authorities authorise and supervise issuers. The European Banking Authority takes over for significant tokens. ESMA writes the technical standards and maintains the interim registers but supervises none of the firms on them; the register itself states that no competent authority has reviewed the white papers it lists. The European Central Bank has an opinion role on asset-referenced token authorisations and has been the most persistent objector to how the regime is applied to globally issued tokens. The Commission proposes the legislation and has so far resolved the hardest interpretive question through an internal question-and-answer procedure rather than a legislative amendment.
Examples
The registers are the primary example, and they should be read as counts of tokens rather than of firms: 46 notified white papers against 20 issuers on 24 July 2026 means several issuers have notified more than one, typically a euro and a dollar version of the same product.
Paxos illustrates the licensing route. It issues Global Dollar through Paxos Issuance Europe under Finnish supervision for MiCA purposes, while running the same product line through separate regulated entities in Singapore and the United States. The structure exists because the authorisation is European and the token is not.
Tether is the counter-example. It holds a digital asset service provider and stablecoin issuer licence from El Salvador and has not taken the electronic money institution route, which is why USDT sits outside the category that the European register measures.
Risks and limitations
Multi-issuance is the unresolved question and the one most likely to decide whether the regime holds. Where an EU entity and a third-country entity issue functionally identical, fungible tokens with a rebalancing mechanism between them, a holder anywhere can redeem from either. Judith Arnal's analysis for CEPS and ECRI sets out the ECB's objection: European reserves could be drained meeting redemptions by non-EU holders, EU supervisors would in substance stand behind a third-country issuer's liabilities, and restrictions on large-scale foreign-currency issuance could be circumvented. The Commission has declined to take a public position, routing the matter into a technical clarification procedure. Arnal treats this as MiCA's first real credibility test: the Commission and industry on one side, the ECB and EBA on the other.
The empty asset-referenced register is a second problem, and not merely a curiosity. A category with no authorised issuers cannot absorb the instruments it was designed for. Commodity- and basket-referenced tokens either restructure to reference a single currency, are documented as securities or funds under other regimes, or are issued outside the European Union. None of that is what the classification intended.
The backing requirement is contested from both directions in the review now under way. Reporting in July 2026 indicates the Commission is considering allowing issuers to hold European government money market instruments, moving the model closer to the American one, while the ECB has pressed for narrower or central-bank-anchored backing and the EBA has defended the existing text. The consultation asks a great many detailed questions without settling the prior one of whether an e-money token is narrow money, private debt, or a claim that ought to be anchored in public money.
Finally, the registers are administrative artefacts rather than judgements. A notified white paper is a filing, not an approval, and counting rows counts products.
Key metrics
The two series that matter are the count of notified e-money token white papers (46 on 24 July 2026, across 20 issuers) and the count of authorised asset-referenced token issuers, which was zero on the same date. Track alongside them the number of tokens designated significant and therefore supervised by the EBA, since that designation is what raises the deposit requirement from 30% to 60% and materially changes issuer economics, and the number of distinct member states that have authorised at least one issuer, which is the measure of whether supervision is converging or fragmenting.
Related research
SUERF Policy Note No 411 is the clearest statement of the internal tension in the e-money token regime. The CEPS and ECRI analysis by Judith Arnal is the reference on multi-issuance and the positions the European institutions have taken on it. Chainalysis has published the most usable practitioner summary of the two categories and their respective obligations.
The data on this site
The series below are the ones that bear directly on this concept. Each carries its own source, cadence and coverage.
We hold fewer than two verified observations for this series, so there is no trend to draw. The underlying figures are published by European Securities and Markets Authority. Cadence: weekly at source. This page will plot them once the history is long enough to mean something.
We hold fewer than two verified observations for this series, so there is no trend to draw. The underlying figures are published by European Securities and Markets Authority. Cadence: weekly at source. This page will plot them once the history is long enough to mean something.