EU to Treat Same-Issuer Stablecoins as Interchangeable: Why It Matters

The European Commission will unveil updated Markets in Crypto-Assets (MiCA) guidance in June 2025 to treat same-brand stablecoins issued outside the EU as interchangeable with those issued inside, despite European Central Bank President (ECB) Christine Lagarde’s warnings that this could expose EU banks to reserve runs.

EU MiCA Stablecoin Market: Size, Reserve Rules and Cross-Border Fungibility

MiCA, adopted in 2023, mandates that EU “e-money tokens” hold most reserves in EU banks to ensure redemptions at par value. However, it left a loophole over tokens issued by the same firm outside the bloc – tokens that now will count as the same asset under the new guidance. ECB President Lagarde cautioned that overseas holders could sweep reserves from EU banks during stress, risking contagion across the financial system.

Stablecoins . . . pose risks for monetary policy and financial stability [and] must therefore be governed by sound rules, especially when they operate across international borders,

ECB president Christine Lagarde told the European parliament.

The global stablecoin market cap stood at about $252 billion by mid-2025, up from $208 billion a month earlier, reflecting sustained demand for dollar-pegged liquidity. Non-EU issuers typically back tokens with U.S. Treasuries (roughly $200 billion of T-bills are held by stablecoin projects today), driving demand in money-market funds. Critics warn national supervisors may apply MiCA unevenly, creating gaps in oversight and reserve-backing standards across member states.

Implications of Fungible Stablecoin Guidance and Next Regulatory Steps

Treating non-EU and EU-issued tokens as identical would simplify cross-border use and lower barriers for global stablecoin adoption. But it may also amplify systemic risk: a sudden rush on any version could drain the same collateral pool, intensifying pressure on EU banks. Brussels argues runs on fully collateralized stablecoins are unlikely and would be managed by national supervisors rather than new EU guarantees.

In the coming weeks, we may expect formal guidance from the Commission and clarifications on how national competent authorities (NCAs) will verify reserve parity by Q3 2025. Stakeholders will watch for any follow-on measures on reserve audits, redemption rights, and interoperability with a future digital euro. Will this approach accelerate institutional stablecoin issuance or trigger fresh calls for global legal safeguards?

Digital Euro and Stablecoins: Interplay and Implications

The digital euro and private stablecoins fall under different regimes; yet MiCA’s guidance, which treats non-EU and EU-licensed tokens as equivalent, could blur that divide. A EuroParliament study shows that without state backing, stablecoins struggle for scale, while a fully backed digital euro commands user trust and policy support. Bank of Italy Governor Fabio Panetta argues that a digital euro – more than MiCA – holds the key to managing crypto risks in Europe:

What is needed is a response that matches the ongoing technological transformation, one capable of meeting the demand for secure, efficient, and accessible digital payment instruments, all while preserving the role of central bank money. The digital euro project stems precisely from this need,

Bank of Italy Governor expressed.

As for ECB President Christine Lagarde, digital euro plays a central role in safeguarding Europe’s financial independence, positioning it as a “public good” contrasted with private tokens. Meanwhile, some Members of the European Parliament (MEPs) warn that fungibility rules create a backdoor for foreign stablecoins that could undermine the CBDC’s unique value proposition. 

Whether this move speeds up stablecoin adoption or creates new problems for the digital euro will depend on how markets and regulators respond. But one thing is clear: the EU now sees stablecoins (even foreign ones) as too important to ignore.