Revolut did not issue its euro stablecoin. Nor have 37 European banks.

Yesterday's piece looked at the distance between a crypto regime being legislated and a licence actually being obtainable, across eleven jurisdictions outside the EU and the United States. Inside the EU that particular gap has closed. MiCA applies, the registers are published weekly, and anyone who wants to issue a euro stablecoin can find out exactly how.

The gap has simply moved one step further down the chain. Europe now has a reasonable supply of authorised issuers and a striking shortage of issued euros. This week produced two good illustrations of it.

Revolut's euro stablecoin is issued by Stripe

In late August 2026 Revolut began a phased rollout of EURR, a euro-pegged e-money token, to customers in Denmark, Poland and Portugal, with wider EEA availability expected later in the year. Most coverage described this as Revolut launching a stablecoin. Revolut's own announcement is more precise, and the precision is the interesting part: EURR is "issued by Bridge Building, a Stripe company" — Bridge Building S.A., a MiCA crypto-asset service provider and electronic money institution regulated by Luxembourg's CSSF — and offered by Revolut Digital Assets Europe Ltd, a CASP regulated by CySEC.

So the token is issued by Stripe's European entity. Revolut distributes it.

That is worth sitting with, because Revolut is not a company that lacks licences. It exited mobilisation as a full UK bank in March 2026, received a French banking licence on 10 August 2026 following a joint ACPR and ECB assessment formally adopted by the ECB's Governing Council, and continues to run its established Lithuanian bank alongside both. If any European fintech had the balance sheet, the regulatory relationships and the in-house capability to issue its own e-money token, it is this one. It chose not to.

We think that was the right call rather than a surprising one, and the reasoning generalises well beyond stablecoins. Issuing an e-money token means running reserve management, redemption obligations, white paper maintenance and a supervisory relationship, for a product that is not — on any evidence available today — where the customer demand is. Renting the issuance and keeping the distribution puts the effort where the differentiation is. It is the same build-versus-use-a-provider question every licensed firm eventually runs into, answered in public by a firm that could plainly have built.

The timing is not accidental either. Revolut disabled USDT purchases for European customers on 6 July 2026, blocked deposits on 30 July, and converts residual balances on 31 August. Tether never sought MiCA authorisation. EURR arrived days before that conversion date, into shelf space MiCA had cleared.

MiCA did not create a licence for issuing a stablecoin

ESMA publishes the interim registers required by Article 109 as weekly files. Reading the e-money token register as last updated on 21 August 2026 gives 23 distinct issuers and 40 notified white papers — the file has 43 rows, but two are placeholders marking an authorised issuer that has not yet published a white paper, and one is a duplicate. Twenty-one of the twenty-three have published one.

They sit in twelve EU member states plus Iceland: France with six issuers, Luxembourg three, Lithuania, Malta and the Netherlands two each, and one apiece in Czechia, Germany, Denmark, Finland, Iceland, Latvia, Poland and Slovenia.

The detail that explains a great deal is in the dates. The register's authorisation date for CACEIS Bank reads 19 May 1979. For Oddo BHF it reads 26 June 2007. Those are not typographical errors and they are not stablecoin authorisations. Article 109(4)(f) says what that field is: the date of authorisation as a credit institution or as an electronic money institution. Fifteen of the twenty-three carry a date earlier than 30 June 2024, when the stablecoin titles of MiCA began to apply at all.

Which is the point. Article 48(1) says a person shall not offer an e-money token to the public in the Union unless that person is authorised as a credit institution or as an electronic money institution, and has notified a white paper to its competent authority. There is no separate MiCA stablecoin licence. There is a licence you already hold, and a document you file.

Two narrow exceptions exist and are worth knowing about, because one of them is live on the register: Article 48(4) and 48(5) disapply the requirement for issuers covered by the small-issuer waiver in the E-Money Directive, and for tokens falling under its limited network or electronic communications exclusions. One of the twenty-three, a Czech issuer, is flagged for both, with the register comment "EMT is issued under the limited network exception". A white paper is still required.

So the barrier to issuing a euro stablecoin in Europe is not authorisation. There are roughly 4,600 credit institutions in the EU and just over 400 authorised e-money institutions across the EEA, and any of them could add one. On the register's own classification most of the twenty-three are e-money institutions rather than banks — which means the actual issuers have been drawn overwhelmingly from the smaller of the two pools. The barrier is that almost nobody has a reason to.

Nobody has been authorised to issue an asset-referenced token

The companion register, for asset-referenced tokens, is empty. Not sparse — empty. The file is a header row and nothing else, and its last-modified timestamp reads 14 February 2025: byte-identical for eighteen months.

An asset-referenced token, under Article 3(1)(6), is one that is not an e-money token and that purports to maintain a stable value by referencing another value or right, or a combination of them, including one or more official currencies. A basket is one case. So is a token referencing a single commodity — tokenised gold is an ART, not an EMT.

Zero authorised issuers, twenty-six months after Titles III and IV began to apply. The register does flag issuers exempt from authorisation as credit institutions under Article 17, and there are none of those either — though a separate exemption in Article 16(2), for issuances under a €5 million twelve-month average and offers to qualified investors only, sits outside the register entirely, so the honest claim is that nobody has been authorised, not that nobody is issuing.

Why does the category sit unused? The requirements are genuinely heavier than for an e-money token: authorisation in its own right rather than reliance on an existing licence, a white paper that must be approved rather than merely notified, own funds and reserve requirements, and restrictions on paying interest. It is worth knowing this before designing a product that would need one. Note that the significance regime is not the differentiator people assume — Article 56 classifies significant e-money tokens on the same criteria, with EBA supervision either way.

What Europe's euro stablecoins add up to

Circle's EURC is the largest by a distance, at €395.9 million on Circle's own reporting for 27 August 2026. Société Générale-FORGE's EURCV is second at about €155 million, up from roughly €127 million a month earlier. Then Banking Circle's EURI at about €33 million, Monerium's EURe at about €28 million, Schuman Financial's EURØP at about €17 million, StablR's EURR at about €13 million, Quantoz's EURQ at about €9 million, Stasis's EURS at about €7 million and the residual Euro Tether at about €4 million. Below that, fifteen tokens share about €9 million between them.

AllUnity's EURAU is the most instructive number here. AllUnity is a joint venture of DWS, Galaxy and Flow Traders; it obtained a BaFin e-money institution licence on 1 July 2025 and launched EURAU on 31 July 2025 as Germany's first MiCA-compliant euro stablecoin. Thirteen months on, its outstanding supply is about €359,000. Nothing in that reflects on the issuer's competence or seriousness — a well-capitalised consortium with a real licence and a working product has found that supply follows demand, and the demand is not yet there. It is a market fact rather than a company one.

Totalled, euro-denominated stablecoin supply is around €673 million. Global stablecoin supply is around $310 billion, of which roughly 99.7% is dollar-denominated. Converted at current rates, euro tokens are about a quarter of one per cent of the market. ECB Executive Board member Piero Cipollone put the dollar's share at 99% in a February 2026 speech titled "Europe and monetary sovereignty", which is close enough.

Thirty-seven banks, and no token yet

The second illustration is Qivalis, the Amsterdam joint venture formed to issue a MiCA-compliant euro stablecoin. Announced in September 2025 with nine founding banks, formalised as a joint venture on 2 December 2025, joined by BNP Paribas that month and BBVA in February 2026, and expanded on 20 May 2026 to thirty-seven institutions — among them ING, UniCredit, CaixaBank, Danske, DekaBank, KBC, Raiffeisen Bank International, SEB and Banca Sella. Fireblocks was named as infrastructure partner in April 2026. The stated target was to launch in the second half of 2026.

Its own website today says: "Qivalis B.V. has applied to De Nederlandsche Bank (DNB) for authorisation as an electronic money institution", and "Qivalis is not yet authorised and does not currently issue electronic money or provide payment services to the public."

Again, not a criticism. Assembling thirty-seven competing banks into one issuing entity, agreeing governance and reserve policy and taking it through a Dutch authorisation process is genuinely hard, and holding that coalition together for eleven months is the notable part. But the arithmetic is worth stating plainly: the largest coordinated banking effort in European stablecoin issuance has so far issued nothing, while a payments company obtained its Luxembourg licences at the end of June and was live inside Revolut by August.

Where this argument is weakest

Three things cut against everything above, and the first is the one we found hardest to write.

The growth story depends heavily on where you start counting. Euro stablecoin supply has gone from about €254 million in August 2024 to €398 million in August 2025 to €681 million now — up roughly 71% year on year and 168% over two years, while dollar supply grew about 82% over the same period. That reads well. But the euro share of the market actually fell in the first of those two years, from 0.149% to 0.141%, before recovering to 0.220%. And euro-pegged supply stood at roughly €637 million in February 2022. On that view the market has spent four years getting back to where it already was, and the two-year growth figure is an artefact of measuring from the bottom.

Some of it is genuine payment use. On-chain classification published by Crystal Intelligence in June 2026 put EURC at around 215,000 holders with roughly 17% of flow classified as money use, and Monerium's EURe at around 47,000 holders with about 9% — the latter running live on Gnosis Pay and MetaMask Card with IBAN in and out. Monerium in particular is a real payments case rather than a collateral instrument.

But the composition tells against the headline. The same analysis put EURCV at roughly 79% collateral flow with about 5% money use and 94% of supply in ten addresses — a block explorer today puts that concentration higher still — and EURI at about 98% exchange flow with 1% money use. The fair reading is that euro stablecoins are working, as collateral and as settlement infrastructure, and are not yet working as payment instruments at any scale that matters, with one or two genuine exceptions.

Why anyone is bothering

Two structural reasons, and one that is more speculative than it is usually presented.

Issuance became a procurement decision. When Bridge obtained its CSSF authorisations at the end of June 2026, issuing a MiCA-compliant euro token stopped being a multi-year licensing programme and became something a distributor could buy. Revolut's choice is the proof: the capability is now purchasable, and a company with two banking licences purchased it.

There is a long gap where the public option should be. The digital euro Regulation is not adopted. The Council agreed its mandate on 19 December 2025, Parliament adopted its position on 9 July 2026, and the first political trilogue was held on 13 July 2026 — with no provisional agreement since. The ECB's own pilot is planned to start in the second half of 2027 and run for twelve months, aiming to be ready for a potential first issuance during 2029, assuming the Regulation is adopted in 2026. Whatever anyone thinks of private euro tokens, that is a long time for the space to be empty.

The interchange argument is a hypothesis. It is widely asserted that stablecoin settlement will compress European card economics. We could not find a single source that quantifies it for Europe, and independent analysis points the other way — Oliver Wyman's May 2026 work notes that stablecoin activity remains 70% concentrated in crypto trading and on-chain liquidity, and that European consumers already have fast, cheap and reliable payment options, which is precisely why stablecoins face more headwind here than in markets with worse rails. Treat the cost story as untested.

What we could not verify

The composition argument rests on one commercial source. The holder counts and money-use percentages come from Crystal Intelligence's own classification taxonomy. We corroborated the concentration finding independently — a block explorer puts EURCV's top ten Ethereum addresses higher than Crystal does — but the flow percentages have no public equivalent and cannot be checked by anyone outside that vendor. It is the argument we would drop first if it turned out to be wrong.

Aggregator data needs care, and we got it wrong before we got it right. The aggregator we used reports euro tokens in dollars in its summary tables and in euros on its per-token pages. An earlier draft of this article mixed the two and overstated most of the market by about a sixth. Every figure above is on the euro basis, and Circle's own reported EURC figure sits within 1% of it. If you are checking our numbers against a headline market-cap column, you will see something roughly 16% larger, and that is the reason.

Two different tokens trade as EURR — StablR's Maltese token, listed above, and the Bridge-issued token distributed by Revolut. They are routinely conflated. We have not put a figure on the latter: reported supply at launch differs by three orders of magnitude between sources, which is what a phased rollout in three countries looks like from outside.

The multi-issuer question is legally unsettled. The European Systemic Risk Board recommended, in a recommendation of 25 September 2025 published on 20 October, that the Commission clarify that third-country multi-issuer schemes are not permitted under MiCA. We found no formal response to that recommendation, though the Commission said publicly in October 2025 that MiCA provides a robust and proportionate framework, and its own MiCA review consultation — open since 20 May 2026 and now closing on 30 September after an extension — asks how multi-issuer models should be handled. Parliament adopted a non-binding report in July 2026 pointing the other way. Anyone telling you this is settled has picked a side.

The registers move weekly and this page will decay. Every count above was read on 29 August 2026 from a register last updated on 21 August. If you are reading this more than a quarter later, check the two or three entries your decision depends on.

What this means in practice

If you are considering issuing a euro stablecoin, the useful question is no longer whether you can get authorised. If you already hold an e-money institution or credit institution licence, you very likely can — that is what Article 48 says. The question is whether you want the reserve management, the redemption obligation and the supervisory relationship attached to a product whose entire European market runs to a few hundred million euros, and whether renting issuance while keeping distribution gets you the same commercial outcome for a fraction of the standing cost.

If you are considering accepting or settling in one, the composition matters more than the supply figure. Most euro stablecoin supply today is collateral and exchange inventory rather than money in motion, and a token with nearly all of its supply in ten addresses behaves differently under stress from one held by fifty thousand people.

We hold no licence and issue nothing, which is our standing disclosure on pieces like this. What we do is connect firms to several licensed institutions rather than one, and this market interests us because it is currently the clearest available example of authorisation and capability being two entirely separate problems. If you have issued a euro e-money token and the experience differed from the picture above — particularly on demand — we would rather hear it than keep publishing our version.