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Asset-Referenced Tokens (ART) Under MiCA — Issuer Guide (2026)

Asset-referenced tokens (ART) under MiCA — issuer requirements

If your token holds its value against a basket of currencies, a commodity, or a mix of assets rather than a single fiat currency, it is an asset-referenced token (ART) — and it sits in MiCA's most demanding issuance regime after EMTs. Under Title III, ART issuers must be authorized before issuing, hold a reserve of assets, meet own-funds requirements, and get their white paper approved by a regulator. This guide walks through every requirement.

What an Asset-Referenced Token Is

An asset-referenced token aims to maintain a stable value by referencing any value or right, or a combination — other than a single official currency. Examples include a token pegged to a basket of currencies, a gold-backed token, or one referencing a mix of crypto and fiat. The defining feature is value stabilisation against something other than one fiat currency (which would make it an e-money token).

If you are unsure whether your token is an ART, an EMT, or a utility token, start with our token classification guide — the answer changes everything below.

Authorization to Issue an ART

Unlike utility tokens, you cannot simply publish a white paper and issue an ART. The issuer must be authorized by its National Competent Authority before offering the token to the public or seeking admission to trading — or be an authorized credit institution following a modified procedure. The authorization assesses the issuer's governance, the reserve arrangements, the redemption mechanism, and the white paper, which the NCA must approve (not merely receive).

This is a full licensing process closer to authorizing a financial institution than to launching a token.

The Reserve of Assets

Every ART must be backed by a reserve of assets that covers the issuer's liabilities to holders. MiCA imposes strict rules on the reserve:

  • It must be segregated from the issuer's own assets and held in custody with qualified custodians;
  • It must be composed of low-risk, liquid assets and managed to preserve value and liquidity;
  • Investment of the reserve is restricted to highly liquid financial instruments with minimal risk;
  • The reserve must be independently audited and transparently reported.

The reserve is the holders' protection, and its composition and custody are central to authorization.

Own Funds Requirements

ART issuers must hold own funds of at least the highest of:

  • €350,000;
  • 2% of the average amount of the reserve assets; or
  • a quarter of the preceding year's fixed overheads.

So a large ART scales its capital with the size of its reserve — a meaningful ongoing commitment. For a significant ART the percentage can be raised by the supervisor. This is separate from, and additional to, the reserve itself.

Redemption Rights & Holder Protection

Holders of an ART have a permanent right of redemption against the issuer — either in funds equivalent to the market value of the referenced assets, or by delivery of the referenced assets. The issuer must establish a clear redemption policy and maintain the reserve and liquidity to honour it. MiCA also restricts granting interest on ARTs.

If the reserve's value diverges from holders' claims, the issuer must act to protect holders — including, in stress, a recovery and redemption plan.

Significant ARTs — EBA Supervision

An ART can be designated significant where it crosses thresholds on holder numbers, market capitalisation, daily transactions, the size of the reserve, or its importance to cross-border activity. Significant ARTs face enhanced requirements — higher own funds (up to 3% of reserve assets), stricter liquidity and interoperability rules — and supervision passes to the European Banking Authority (EBA).

Because designation has major consequences, scale-oriented ART projects should plan for the significant regime from the start. We help structure ART issuance and the ART license with that trajectory in mind.

Frequently Asked Questions

What is an asset-referenced token under MiCA?
An asset-referenced token (ART) is a crypto-asset that maintains a stable value by referencing any value or right, or a combination — such as a basket of currencies, a commodity like gold, or a mix of assets — other than a single official currency. ARTs are governed by MiCA Title III and require issuer authorization.
Do you need a license to issue an ART?
Yes. Unlike utility tokens, an ART issuer must be authorized by its National Competent Authority before offering the token to the public or seeking admission to trading, or be an authorized credit institution. The NCA must also approve the white paper. It is a full licensing process.
What capital does an ART issuer need?
An ART issuer must hold own funds equal to the highest of €350,000, 2% of the average amount of the reserve assets, or a quarter of the preceding year's fixed overheads. For significant ARTs the percentage can be raised by the supervisor. This is separate from and additional to the reserve of assets backing the token.
How is an ART different from a stablecoin (EMT)?
An e-money token references a single official currency and can only be issued by a credit institution or EMI, with redemption at par. An asset-referenced token references any other value or a basket and requires the issuer to be specifically authorized, hold a reserve of assets, and meet own-funds requirements scaled to the reserve.
What makes an ART significant?
An ART is designated significant when it crosses thresholds on factors such as the number of holders, market capitalisation, daily transactions, the size of the reserve, or cross-border importance. Significant ARTs face higher own funds (up to 3% of reserve assets) and stricter rules, and are supervised by the European Banking Authority.
ART & Token Issuance Specialist
Elena Fischer
Senior Compliance Advisor · Düsseldorf & Luxembourg

Elena Fischer advises issuers of asset-referenced tokens on MiCA Title III authorization, reserve-of-assets design, white-paper approval, and the significant-ART regime supervised by the European Banking Authority. Speak with our team →

Issue an Asset-Referenced Token the Right Way

We guide ART issuers through MiCA Title III authorization, reserve-of-assets and custody design, own-funds structuring, and white-paper approval — including planning for the significant-ART regime. Free 30-minute consultation.

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