The field guide
Services involving non-compliant stablecoins
A source-led reading, not an enforcement finding against a named firm.
- Sheet
- 048
- Section
- Supervisory notices
- Instrument
- Radar scope
- Edition
- 12 · XI · 2026
The January 2025 ESMA and Commission guidance concerns the treatment of services relating to non-MiCA-compliant ARTs and EMTs. It is not a blanket statement that every token or every service has identical treatment. [ESMA]
Operating implications
Identify the exact asset, issuer, EU service entity and activity. Retain the applicable terms and regulatory source rather than relying on a global product listing.
What not to infer
The statement is not a substitute for checking the actual entity and service. It does not certify the status of a provider or guarantee a transaction. Read the original document and distinguish its publication date from any application or transition deadline.
Method, assumptions and limits
Regulatory facts are linked to primary sources. Suggested workflows are our editorial synthesis; examples and fee scenarios are hypothetical. The mechanical illustration is a conceptual navigation aid, not a prescribed legal funds flow.
This is a dated research edition, not an automatically updated register or live price feed. Check the applicable entity, service, jurisdiction and source version before using the material.
Read the methodologySources & scope
Research snapshot: 12 November 2026. The dated rule, its scope and the legal entity matter. Open the primary source before acting.
- ESMA: Guidance on non-MiCA-compliant ARTs and EMTs, 17 January 2025Supervisory statement
- EUR-Lex: Regulation (EU) 2023/1114 — Markets in Crypto-AssetsEU legislation
- ESMA: MiCA implementation and the central registerRegulator register and guidance