Choosing a stablecoin settlement provider

Key facts (as of 29 October 2026)

• EU: MiCA's transitional period is over. Firms outside the EU may not provide MiCA services to EU clients outside narrow reverse solicitation, which ESMA says "also applies in a business-to-business context". ESMA's interim CASP register file (last updated 22 October 2026, read 29 October) had 387 entries covering 384 distinct firms (ESMA register).
• UK: the FCA's cryptoasset regime under the FSMA (Cryptoassets) Regulations 2026 goes live on 25 October 2027 (FCA). Until then, UK firms need MLR registration with the FCA for cryptoasset activity.
• US: the OCC's GENIUS Act rule takes effect on 18 January 2027 (OCC Bulletin 2026-50).
• Travel Rule: FATF's July 2026 update found 83% of jurisdictions assessed had passed Travel Rule legislation, up from 73% in 2025.

What a provider does

The licence check

flowchart TD
    A[Where are you and your clients?] --> B{EU clients?}
    B -- Yes --> C[Provider must be a MiCA CASP: check ESMA register]
    B -- No --> D{UK?}
    D -- Yes --> E[FCA registration now; authorisation under new regime from 25 Oct 2027]
    D -- No --> F{US?}
    F -- Yes --> G[State money transmission licences, NYDFS where relevant; GENIUS status for issuers]
    F -- No --> H[Local VASP licence or registration]
    C --> I[Verify the exact legal entity that contracts with you]
    E --> I
    G --> I
    H --> I

WarningLicences attach to a specific legal entity. A group may hold a licence in one country and contract with you from another. Check the entity named in your contract against the register.

Scored checklist

Red flags

NoteAsk how the provider treats your sector. High-risk merchants need a provider with a written policy for them, not one that has never been asked.

Illustrative example: comparing two providers

Illustrative example. The providers and scores are invented.

A Malta-licensed operator compares two providers. Provider A is an authorised CASP in Ireland, offers USDC and EURC on Ethereum and Solana, segregates client assets, supports the Travel Rule and has a written gambling policy. Provider B is offshore, cheaper, supports USDT on Tron and cannot name its EU-licensed entity. A scores 4.3 out of 5; B scores 2.6, failing on licensing. The operator picks A and keeps a second authorised provider as backup.

Timeline

Q/A

Should we use one provider or two?

Two, where volumes justify it. Concentration is a common failure point.

How do we check custody?

Ask for the legal structure, safeguarding terms, audit or assurance reports and key-management controls.

What contract terms matter most?

Notice periods, what happens to your assets if the provider fails or exits, and access to data.

Does a provider's licence cover our clients?

Only for the activities and places it covers.

Sources

• ESMA, statement on the end of transitional periods under MiCA (17 April 2026): https://www.esma.europa.eu/sites/default/files/2026-04/ESMA75-113276571-1679_Statement_on_the_end_of_transitional_periods_under_MiCA.pdf
• ESMA, MiCA page and interim register: https://www.esma.europa.eu/esmas-activities/digital-finance-and-innovation/markets-crypto-assets-regulation-mica
• Regulation (EU) 2023/1114 (MiCA): https://eur-lex.europa.eu/eli/reg/2023/1114/oj
• FCA, PS26/10 stablecoin issuance (30 June 2026): https://www.fca.org.uk/publication/policy/ps26-10.pdf
• OCC Bulletin 2026-50: https://www.occ.gov/news-issuances/bulletins/2026/bulletin-2026-50.html
• FATF, 7th targeted update on virtual assets (July 2026): https://www.fatf-gafi.org/en/news/targeted-updated-va-vasps-2026.html