Third-country multi-issuer stablecoins

Abstract Technical, market, and regulatory fragmentation drive cooperation in decentralised finance globally. This paper focuses on the third country multi-party issuance of stablecoins under the Markets in Crypto-Assets Regulation (MiCA). It identifies the parallel issuance and syndicate models as legally accepted archetypes of crypto cooperation under MiCA and analyses the corresponding regulatory requirements. The discussion addresses the need for a policy response to multi-issuer crypto schemes involving third-country issuers as requested in October 2025 by the European Systemic Risk Board. Token holder protection calls for detailed disclosures on the participating parties and their accountability, and an appropriate organisational structure for cooperation should be ensured. Systemic risk concerns warrant a close look at reserve handling and outsourced relationships with technical service providers and developer firms. However, an objective-based interpretation of Article 34 MiCA, Article 5(1)(l), 19(6) of the second Payment Services Directive (PSD2), and the application of the Digital Operational Resilience Act (DORA) provide the means to mitigate such risks. Looking ahead, the integration of important crypto infrastructure providers in the Eurosystem framework for financial market infrastructure, as well as the introduction of a substituted compliance/equivalence framework into MiCA, would further strengthen regulatory coherence.