The European Securities and Markets Authority on 8 October told national supervisors that MiCA-authorised crypto firms should stop providing services in stablecoins that do not meet the EU rulebook. The opinion, ESMA75-113276571-1742, covers asset-referenced tokens and e-money tokens. It does not name a coin. It sets a clock.

National competent authorities should require firms to clear remaining client exposure as soon as possible, and no later than three months after publication. That outside date is 8 January 2027. Until then, a firm may keep only the services a client needs to get out: liquidation, conversion, withdrawal, transfer, or safekeeping. Those services have to be time-limited, risk-based, and closely supervised. They cannot be used for new purchases or promotion.

The scope is wider than a delisting. ESMA’s press notice lists trading platforms, exchange services, order execution, placement, reception and transmission of orders, investment advice, transfers, custody and administration, and portfolio management. The opinion says the problem does not turn on whether each service is itself a public offer or an admission to trading. An authorised firm that keeps a non-compliant token usable or liquid for EU clients is, in ESMA’s view, facilitating exposure the Titles III and IV safeguards were written to prevent.

That is the change from the earlier guidance. Custody and transfers had been the residual. The 8 October text pulls both inside the supervisory expectation. Firms are expected to put technical, contractual, and organisational controls in place so EU clients cannot acquire or increase exposure. ESMA will monitor how national regulators apply the opinion. It did not publish a common EU list of affected tokens, and it did not prescribe one technical implementation.

The opinion is addressed to supervisors. It is not a new statute, and it is not an EU-wide ban on holding a token in a private wallet. It is a direction to the firms that already hold a MiCA licence: stop offering the non-compliant stablecoin, and wind down what is already on the book by 8 January 2027.

ESMA does not name Tether’s USDT. Secondary tallies of the ESMA e-money token register, checked against the register this week, still do not list Tether as an authorised issuer. Circle’s USDC and EURC are on that register through Circle Internet Financial Europe, a French e-money institution. Paxos’s USDG and Société Générale’s EURCV are also among the notified tokens. The legal test in the opinion is the one that matters for a desk: if the conditions for a lawful EU public offer or admission to trading are not met, including exemptions and transitional arrangements, the token is in scope. USDT is the largest coin that fails that test. It is not the only one.

The same month has a second EU stablecoin file, and it cuts the other way. On 22 September the European System of Central Banks — the ECB and the 27 national central banks — told the Commission that MiCA’s bank-deposit reserve rule should be dropped. Issuers must currently hold 30% of reserves as bank deposits, or 60% if the token is significant. The central banks said that requirement can leave lenders exposed to a stablecoin run. They want a minimum share in assets that mature within one to five working days instead. They also want the ban on paying yield on stablecoins extended to lending, borrowing, and staking, on the argument that e-money is for payments, not savings. And they repeated the European Systemic Risk Board’s line that multi-issuance models — a global firm treating an EU token as interchangeable with a non-EU token — are not allowed under the current rules.

Read together, the two documents are not a single policy. ESMA is closing the service layer around tokens that never got a MiCA authorisation. The central banks are trying to rewrite the reserve and yield rules for the tokens that did. One is an opinion with a January deadline. The other is a consultation response, not a rule change. Neither legalises a non-EU stablecoin, and neither confiscates coins already in self-custody.

For EU clients the practical line is the authorised platform. Buying, trading, and — under this opinion — custody and transfers of a non-compliant stablecoin through a MiCA firm are what supervisors are being told to stop. Selling, converting, and withdrawing during a supervised wind-down are what the three months are for. After 8 January 2027, the residual book is the thing national regulators were told not to leave in place.

Sources:

ESMA press release, 8 October 2026: https://www.esma.europa.eu/press-news/esma-news/esma-sets-out-supervisory-expectations-services-related-unauthorised

ESMA opinion ESMA75-113276571-1742 (PDF): https://www.esma.europa.eu/sites/default/files/2026-10/ESMA75-113276571-1742_Opinion_on_the_provision_of_crypto_asset_services_in_relation_to_non-MiCA-compliant_asset-referenced_tokens_and_e-money_tokens.pdf

Reuters, 22 September 2026, ECB and EU central banks on the deposit rule: https://www.reuters.com/business/finance/ecb-eu-central-banks-oppose-stablecoin-bank-deposit-rule-2026-09-22/