Purpose This paper aims to clarify whether multi-issuance stablecoin structures, jointly issued across European Union (EU) and non-EU jurisdictions, are compatible with Markets in Crypto-Assets Regulation (MiCA). It provides an analytical framework for understanding the institutional standoff between the European Central Bank (ECB), Commission and Parliament, assessing broader competitive and consumer protection consequences. The paper demonstrates that MiCA already contains necessary legal instruments – Recital 54, Articles 54–56 and Level 2 implementing measures – to accommodate multi-issuance arrangements. It proposes immediate Commission Question and Answer (Q&A) clarification and medium-term legislative codification via the Savings and Investment Union (SIU) package trilogue or, more naturally, the MiCA review under Articles 140 and 142 launched in May 2026, to resolve regulatory paralysis while safeguarding EU credibility in global digital finance. Design/methodology/approach The paper adopts a doctrinal and institutional analytical approach, combining legal interpretation, policy analysis and comparative assessment. MiCA’s provisions (Recital 54, Articles 54–56 and Level 2 implementing measures) are examined in light of core EU legal principles and contextualised through preparatory works and emerging supervisory practices. A comparative perspective contrasts MiCA’s proportional reserve framework with the U.S. GENIUS Act, focusing in particular on equivalence and reciprocity mechanisms, cross-border issuance rules, reserve requirements and supervisory structures, to assess their implications for global regulatory competition in stablecoins. Findings MiCA’s provisions – Recital 54, Articles 54–56 and Level 2 implementing measures – provide a legal basis for multi-issuance through proportional reserve allocation, cross-referencing between asset-referenced tokens and electronic money tokens, and aggregated supervision. Comparative analysis reveals that the GENIUS Act’s Section 18 statutory clarity on cross-border issuance contrasts sharply with EU interpretive uncertainty, creating competitive disadvantages. While ECB prudential concerns are valid, outright exclusion would paradoxically weaken consumer protection by pushing users to offshore alternatives, distort competition favouring early movers, and cede ground to jurisdictions with predictable frameworks. Immediate Commission Q&A clarification and medium-term legislative codification through either the SIU package trilogue or the MiCA review would safeguard financial stability while preserving MiCA’s global credibility. Commission’s acknowledgement in its May 2026 review consultation that multi-issuance is not prohibited under MiCA supports this paper’s core interpretation, though binding clarification remains pending. Originality/value This paper provides the first comprehensive legal and comparative analysis of multi-issuance stablecoins under MiCA. It advances an original interpretation demonstrating that Recital 54, Articles 54–56 and Level 2 implementing measures already accommodate cross-border structures, contrasting this framework with the GENIUS Act’s Section 18 equivalence and reciprocity provisions. Beyond doctrinal analysis, it proposes an actionable two-track framework: immediate Commission Q&A clarification and medium-term legislative codification via the December 2025 SIU package or the ongoing MiCA review, establishing both statutory multi-issuance rules and equivalence regimes for third-country issuers. Its value lies in transforming MiCA’s first institutional stress test into regulatory leadership, demonstrating how calibrated integration – not defensive exclusion – safeguards consumer protection, competitiveness and global credibility.
Judith Arnal (Wed,) studied this question.