The European Union faces a critical choice: either allow the uncontrolled exclusion of global stablecoins from its jurisdiction, or develop a mechanism for their managed integration. This dilemma is becoming a central theme in discussions around the regulation of digital assets under the MiCA (Markets in Crypto-Assets) regulation.
Key Issue: Multi-Issuance and Cross-Border Issuance
At the center of attention are multi-issuance structures—situations where the same stablecoin is simultaneously issued both within the EU and outside it. Crypto policy specialist Patrick Hansen emphasizes that the European Union's choice is not between risk and safety, but between "unmanaged exclusion and managed integration."
According to a new study published in the Journal of Financial Regulation and Compliance, MiCA was originally designed to regulate global stablecoins, not to drive them out of the market. The regulation already contains built-in protective mechanisms: segregated reserves in the EU, broad supervisory powers, and quantitative limits on the use of unbacked stablecoins in payments. According to experts, these measures form a solid foundation for prudential protection.
Two-Stage Approach: From Clarifications to Legislation
Hansen fully supports the proposal for a two-stage EU response. The first stage is an urgent clarification from the European Commission in a "Questions and Answers" (Q&A) format. This is necessary to restore a unified approach among national regulators, who currently interpret MiCA norms differently.
The second stage is a legislative amendment to MiCA. It should enshrine the rules for multi-issuance and establish equivalence frameworks for regulatory regimes in third countries. In the medium and long term, this will become an alternative to multi-issuance itself, creating clear and predictable conditions for all market participants.
Competition with the US: The GENIUS Act as a Benchmark
The study directly compares the MiCA approach with the American GENIUS Act. The conclusion is unfavorable for Europe: the American law clearly and explicitly sets out the rules for cross-border stablecoin issuance, whereas in the EU they remain uncertain. It is this gap that puts the European Union at a competitive disadvantage.
The study's author warns that a complete ban on global stablecoins would be counterproductive. It would only weaken consumer protection by pushing them toward offshore services. Instead, a thoughtful inclusion of such assets into the system is proposed, rather than a defensive ban. This would preserve the competitiveness of the European market and the authority of the regulation itself on the global stage.
My Expert Assessment: The situation surrounding MiCA is the first serious stress test for European crypto regulation. The outcome of this discussion will determine whether the EU can remain an attractive jurisdiction for global players or risks becoming an isolated market with limited opportunities. I recommend market participants closely monitor developments—the next 6–12 months will be decisive for the future of stablecoins in Europe.