The European Union needs to clarify the rules for global multi-issuance stablecoins under the MiCA regulation as quickly as possible. The choice, essentially, is not between risk and safety, but between "uncontrolled exclusion" and "managed integration." This is the conclusion reached by crypto policy expert Patrick Hansen, commenting on a fresh research paper dedicated to this issue.
The discussion concerns so-called multi-issuance structures—where the same stablecoin is issued simultaneously both within the EU and outside its borders. Hansen, a well-known specialist in crypto regulation, draws attention to a new academic article which, in his opinion, "hits the very core of the regulatory tension."
The EU Dilemma: Protection or Competitiveness
The key point Hansen cites is that MiCA was originally designed to bring global stablecoins under EU regulation, not to push them out of the market. The regulation already contains built-in protective mechanisms: segregated reserves within the EU, broad supervisory powers, and quantitative limits on the use of non-euro stablecoins in payments. These measures, according to the expert, provide a solid foundation for prudential protection.
However, the problem lies elsewhere. Unlike the U.S. GENIUS Act, which clearly outlines rules for cross-border issuance, MiCA leaves this area uncertain. It is this legal vacuum, as noted in the study, that puts the European Union at a competitive disadvantage.
A Two-Step Plan: From Clarifications to Amendments
Hansen fully supports the recommendation for a two-step EU response. The first step should be an urgent clarification from the European Commission in a "questions and answers" (Q&A) format. This would restore a unified approach among national regulators, who currently interpret MiCA requirements differently.
The second, more fundamental step, should be a legislative amendment to MiCA. It would solidify the rules for multi-issuance and the equivalence framework for third-country regulatory regimes. In the medium and long term, this would become an alternative to multi-issuance itself, creating clear and understandable conditions for all market participants.
The author of the study emphasizes that a complete ban on such stablecoins would have a counterproductive effect. It would only weaken consumer protection, pushing them toward unregulated offshore services. A well-thought-out inclusion of global stablecoins within the legal framework, rather than a protective ban, would preserve the competitiveness of the European market and the authority of the MiCA regulation itself on the global stage.
Analyst's opinion: This situation is the first serious stress test for MiCA. The EU finds itself facing a classic dilemma: either it adapts its rules to the realities of the global market, risking loss of control, or it takes a hardline stance, risking the loss of innovation and liquidity. The current uncertainty is the worst possible scenario, and it is hindering the development of the entire sector.