Key takeaways
- Under Article 48 of MiCA, e-money tokens are deemed electronic money, may be offered by credit institutions and e-money institutions, and remain subject to Titles II and III of the E-Money Directive unless MiCA says otherwise.
- Funds an EMI receives for e-money tokens are safeguarded under Article 7 of the E-Money Directive and must also meet Article 54 of MiCA.
- At least 30% of those funds must always be deposited in separate accounts at credit institutions; the rest must be in secure, low-risk, highly liquid instruments in the token's currency.
- An EMI issuing a significant e-money token follows MiCA's reserve rules in Articles 36, 37, 38 and 45(1) to (4) instead of Article 7 of the E-Money Directive.
- Issuers may not pay interest on e-money tokens, and must redeem them at any time and at par value.
What are the key facts on EMT reserves for EMIs?
An EMI that issues e-money tokens runs its existing e-money safeguarding regime with an extra MiCA layer on top, which changes where token funds can sit.
| Item | Position |
|---|---|
| Rules | MiCA Articles 48 to 58; E-Money Directive (EMD2) Article 7 |
| Regulators | National competent authorities; the EBA for significant tokens |
| Applies to | Electronic money institutions issuing e-money tokens (EMTs) |
| Core test | At least 30% of funds received in separate accounts at credit institutions at all times |
| Last checked | 11 October 2026, against the MiCA text in ESMA's interactive single rulebook |
Why does EMD2 still apply to e-money tokens?
Because MiCA deems e-money tokens to be electronic money and keeps the E-Money Directive's issuance and safeguarding rules in place for them.
Article 48(1) of MiCA allows an e-money token to be offered to the public or admitted to trading only by its issuer, authorised as a credit institution or an e-money institution, which has notified and published a crypto-asset white paper. Article 48(2) deems e-money tokens to be electronic money, and Article 48(3) applies Titles II and III of the E-Money Directive to them unless MiCA provides otherwise. Article 48(6) requires the issuer to notify its competent authority at least 40 working days before the offer or admission. For an EMI, that brings the e-money safeguarding duty in Article 7 of EMD2 straight into token issuance.
What does Article 54 add?
A 30% minimum in bank deposits at all times, and strict limits on what the remaining funds can be invested in, and in which currency they are held.
Article 54 applies to funds received by issuers of e-money tokens in exchange for tokens and safeguarded under Article 7(1) of EMD2. It requires that at least 30% of the funds received is always deposited in separate accounts in credit institutions, and that the remaining funds are invested in secure, low-risk assets that qualify as highly liquid financial instruments with minimal market, credit and concentration risk, in accordance with Article 38(1), and denominated in the same official currency as the one referenced by the token.
| Element | EMD2 Article 7 alone | With MiCA Article 54 |
|---|---|---|
| Methods | Segregation in a credit institution account or secure, liquid, low-risk assets; or insurance or guarantee | Segregated funds must meet the split below |
| Bank deposits | No minimum share | At least 30% of funds received, always, in separate accounts at credit institutions |
| Other assets | Secure, liquid, low-risk assets as defined nationally | Highly liquid instruments with minimal market, credit and concentration risk, under Article 38(1) |
| Currency | Not specified | Same official currency as the token references |
What changes if the token becomes significant?
The EMI moves to MiCA's full reserve regime instead of EMD2 safeguarding.
Under Article 58(1), an EMI issuing a significant e-money token is subject to Articles 36, 37, 38 and 45(1) to (4) of MiCA instead of Article 7 of EMD2, and to Articles 35(2), (3) and (5) and 45(5) instead of Article 5 of EMD2. Article 36 requires a reserve of assets maintained at all times, legally and operationally segregated from the issuer's estate, valued at market prices at no less than the aggregate claims of holders, with an independent audit every six months; for significant e-money tokens, Article 58 runs that six-monthly audit from the date of classification as significant. Under Article 58(2), the competent authority may require an EMI issuing a non-significant token to meet any of those requirements where necessary to address the risks they target.
What rights do token holders have?
A direct claim on the issuer, issuance at par, redemption at par at any time, and no interest or interest-like benefits from the issuer or service providers.
Under Article 49, holders have a claim against the issuer, which must issue tokens at par value on receipt of funds and redeem them at any time and at par value, generally free of charge. Article 50 prohibits the issuer from granting interest on e-money tokens, despite the exception in Article 12 of EMD2, and treats any benefit linked to the length of time a holder keeps the token as interest. Crypto-asset service providers may not grant interest on services related to e-money tokens either. Our guide to MiCA reserve of assets covers the asset-referenced token side.
How does an EMI split its token funds?
It holds at least 30% in bank deposits and the rest in eligible instruments, recalculated as tokens are issued and redeemed.
Worked example. A euro e-money institution has EUR 120.0 million of e-money tokens outstanding, all funds safeguarded by segregation.
| Holding | EUR m | Share | Article 54 test |
|---|---|---|---|
| Separate safeguarding account at credit institution A | 22.0 | 18.3% | Counts toward the 30% |
| Separate safeguarding account at credit institution B | 16.0 | 13.3% | Counts toward the 30% |
| Euro-denominated government bills, highly liquid | 70.0 | 58.3% | Eligible remainder |
| US dollar money market fund units | 12.0 | 10.0% | Fails: not in the token's currency |
| Total | 120.0 | 100% |
Deposits are EUR 38.0 million, or 31.7%, so the 30% floor is met. The US dollar fund units fail the currency rule and must be replaced with euro instruments. If holders then redeem EUR 20.0 million and the EMI pays from deposits, deposits fall to EUR 18.0 million against EUR 100.0 million outstanding, 18%, so it must sell eligible instruments the same day to restore deposits to at least EUR 30.0 million. The floor applies always, not only at month end.
How does the 30% floor interact with redemptions?
Redemptions are usually paid from deposits, so the floor has to be managed as tokens are burned, not checked once a month.
Holders can redeem at any time and at par, so the EMI needs cash available for redemption at short notice. Paying redemptions from the deposit accounts is the natural route, but every payment reduces the deposit share. The EMI therefore needs a rule for rebalancing: for example, selling eligible instruments whenever the deposit share falls below an internal trigger set above 30%, such as 35%. The trigger gives time to settle sales before the legal floor is reached. Concentration also matters: Article 54 requires minimal concentration risk in the invested remainder, and holding all deposits at a single credit institution exposes the reserve to that bank's failure.
What must the EMI tell its regulator before issuing?
It must notify its competent authority at least 40 working days before the offer or admission to trading, and publish a crypto-asset white paper first.
Under Article 48(1) and (6), an EMI may offer an e-money token to the public or seek its admission to trading only after notifying and publishing a crypto-asset white paper, and must notify its competent authority at least 40 working days before the intended date. The safeguarding and investment arrangements that will meet Article 54 should be settled before that notification, because the competent authority will expect the EMI's existing safeguarding framework to extend to the token funds from the first issuance.
What does this mean for daily operations?
Token supply, safeguarding accounts and investments must be reconciled together every day, at one cut-off.
An EMI issuing tokens on public blockchains has three moving records: tokens outstanding on each network, cash in safeguarding accounts, and the instruments held. Mints add funds; burns on redemption remove them. Each must be matched to a movement in the safeguarded funds, and the 30% ratio recalculated after each material change. An EMI that also issues ordinary e-money should keep the token funds identifiable, because Article 54 applies to funds received in exchange for e-money tokens, not to its other e-money float. Our guide to stablecoin reserve reconciliation describes the daily process.
Tokens issued on more than one blockchain add a further step. Supply must be read on every network at the same cut-off, tokens held in the issuer's own wallets excluded, and bridged tokens counted once. Only then can the outstanding amount be compared with the safeguarded funds and the 30% share calculated on the right base.
What should an EMI issuing tokens check?
These checks combine EMD2 safeguarding with the MiCA overlay, from notification to daily reconciliation of token funds.
- Notify the competent authority at least 40 working days before offering the token, and publish the white paper.
- Identify funds received for tokens separately from other e-money funds.
- Keep at least 30% of token funds in separate accounts at credit institutions at all times.
- Invest the rest only in highly liquid, low-risk instruments in the token's currency.
- Redeem at par at any time and pay no interest or time-linked benefits.
- Monitor significance indicators and prepare for Articles 36 to 38 if the token becomes significant.
- Reconcile on-chain supply to safeguarded funds and recheck the 30% floor every day.
How does Safeheld help?
Safeheld reconciles token supply, safeguarding accounts and investments every day by entity and currency, and shows the deposit share against the 30% floor.
See daily reconciliation and PSD3 and safeguarding.
Frequently asked questions
Do EMD2 safeguarding rules apply to e-money tokens?
Yes. MiCA deems e-money tokens to be electronic money and applies Titles II and III of the E-Money Directive to them unless MiCA provides otherwise, so funds received are safeguarded under Article 7 of EMD2.
What does MiCA Article 54 require?
At least 30% of funds received for e-money tokens always deposited in separate accounts at credit institutions, with the rest in secure, low-risk, highly liquid instruments denominated in the token's currency.
What happens when an e-money token becomes significant?
An EMI issuing it becomes subject to MiCA Articles 36, 37, 38 and 45(1) to (4) instead of Article 7 of EMD2, including a reserve audit every six months.
Can an EMI pay interest on e-money tokens?
No. Article 50 of MiCA prohibits interest, and any benefit linked to how long a holder keeps the token counts as interest.
Must e-money tokens be redeemed at par?
Yes. Article 49 requires issuance at par on receipt of funds and redemption at any time and at par value.
Who can issue e-money tokens in the EU?
Credit institutions and electronic money institutions that have notified and published a crypto-asset white paper, under Article 48 of MiCA.
Does Article 54 apply to an EMI's ordinary e-money float?
No. Article 54 applies to funds received in exchange for e-money tokens. Ordinary e-money remains safeguarded under Article 7 of the E-Money Directive alone, so token funds should be identifiable separately.
Can a competent authority apply significant-token rules to a smaller token?
Yes. Under Article 58(2) it may require an EMI issuing a non-significant token to meet any of the significant-token requirements where necessary to address the risks they target.
References
- Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA)
- ESMA interactive single rulebook, MiCA Article 48
- ESMA interactive single rulebook, MiCA Article 54
- ESMA interactive single rulebook, MiCA Article 58
- ESMA interactive single rulebook, MiCA Article 36
- Directive 2009/110/EC (EMD2)
About Safeheld
Safeheld is reconciliation and regulatory financial control software for regulated firms that hold client money. For e-money institutions issuing tokens it reconciles on-chain supply, safeguarding accounts and investments every day and tracks the MiCA deposit floor. To discuss your token operations, contact us at safeheld.com/contact.
This article is general information on EU crypto-asset and e-money rules and is not legal or regulatory advice.