The European Union urgently needs to clarify the regulatory framework for global stablecoins, especially in the context of multi-issuance—when the same asset is issued both within the EU and outside its borders. Regulatory uncertainty on this issue creates serious risks for market integrity and the competitiveness of the European jurisdiction.
Leading crypto policy expert Patrick Hansen emphasizes that the choice for the EU is not between risk and safety, but between "uncontrolled exclusion and managed integration." He stresses that MiCA was originally designed to regulate global stablecoins, not to drive them out of the market. The regulation already includes protective mechanisms: segregated reserves in the EU, broad supervisory powers, and quantitative limits on the use of non-euro stablecoins in payments. According to the expert, these measures create a solid foundation for prudential protection.
A Two-Step Plan to Overcome Uncertainty
Hansen fully supports the recommendation for a two-step EU response. The first step should be an urgent clarification from the European Commission in the form of a "questions and answers" (Q&A) document to restore a unified approach among national regulators. The second, more fundamental step, should be a legislative amendment to MiCA that will enshrine rules for multi-issuance and equivalence frameworks for regulatory regimes of third countries. In the medium and long term, this will become an alternative to multi-issuance itself, creating clear and predictable conditions for market participants.
The analytical work cited by Hansen, published in the Journal of Financial Regulation and Compliance, provides an in-depth analysis of the compatibility of multi-issuance structures with MiCA. The author argues that MiCA already contains the necessary legal tools, including relevant articles and Level 2 measures. However, an institutional deadlock between the European Central Bank (ECB), the European Commission, and the European Parliament is hindering their application.
The article also draws a comparison with the US GENIUS Act, which clearly and explicitly outlines rules for cross-border issuance. In the EU, these rules remain uncertain, putting the Union at a competitive disadvantage. A complete ban on such stablecoins, according to the author, would be counterproductive and would only push users toward offshore services, weakening consumer protection. A thoughtful inclusion of global stablecoins within the system, rather than a protective ban, will preserve competitiveness, the authority of the regulation, and consumer protection.
Cryptalist Comment: The current situation is the first major stress test for MiCA. How the EU handles this challenge will determine not only the future of stablecoins in the region but also the global regulatory standard. Delays in clarifying the rules could lead to an outflow of liquidity and innovation to more favorable jurisdictions, such as the US.