ESMA Expectations for Non-MiCA-Compliant Stablecoins: Covered Services, the Three-Month Legacy Window, and How to Check a CASP

On 8 October 2026 ESMA published a news release and Opinion ESMA75-113276571-1742 on how national competent authorities should supervise crypto-asset services in asset-referenced tokens (ARTs) and e-money tokens (EMTs, meaning stablecoins) that do not comply with the Markets in Crypto-Assets Regulation. The audience is CASPs already authorised under MiCA. The opinion is not an application guide, and it does not, in the text checked here, name a particular stablecoin.

The release says authorised CASPs should cease providing services related to non-MiCA-compliant stablecoins to clients in the European Union. NCAs should see that firms neither maintain, introduce nor facilitate client access to those tokens, and that CASPs use technical, contractual and organisational controls so clients do not acquire or increase exposure. A CoinDesk report the same day summarised the window as three months. Use the ESMA opinion as the source.

The ESMA release lists operation of trading platforms, exchange services, execution of orders, placing, reception and transmission of orders, investment advice, transfers, custody and administration, and portfolio management. The expectation applies whether those services are provided alone or together.

NCAs are expected to assess whether an authorised CASP in their jurisdiction still provides services in non-MiCA-compliant ARTs or EMTs, or maintains or facilitates availability of those tokens to clients in the Union. Any continuation should be limited to what an orderly wind-down and client protection require, and should stay time-limited, risk-based and closely supervised.

The release says that where NCAs identify remaining pre-existing exposures, they should require remediation as soon as possible and no later than three months after publication of the opinion. The opinion date is 8 October 2026. The opinion limits continued services to sell-only, conversion, transfer or withdrawal functions needed to avoid client detriment. The release's list also includes liquidation and safekeeping. Both say the arrangement must not be used to acquire more or to increase exposure.

The three months are ESMA's supervisory expectation for NCAs. The documents checked here do not publish a redemption price or a token-by-token delisting list. The date a given platform closes buys and leaves only sells is for that platform and its NCA.

The opinion does not list crypto cards as a separate MiCA service, and the release checked here does not name USDT. An EU user who funds or spends a crypto card with USDT cannot read the opinion as either a shutdown of that card or a statement that the card is unaffected. Ask the issuer whether the funding or spend is a MiCA service to EU clients, whether that stablecoin is treated in its arrangement as a non-MiCA-compliant ART or EMT, and whether an existing balance is limited to sell, conversion or withdrawal.

Holding a token in a personal wallet is not the same act as a CASP offering trading, custody or transfer to EU clients. This page does not decide whether any stablecoin issuer meets the MiCA EMT or ART conditions.

Authorisation sits with each member state's NCA. The public consolidated entry point is ESMA's Interim MiCA Register, described on ESMA's MiCA page. An entry confirms the status ESMA has consolidated. It does not replace the list of services that firm is authorised to provide.

Hong Kong's licensed stablecoin issuers and Singapore's stablecoin-issuance consultation are different regimes. See those wiki entries. The licence names are not interchangeable.