New Liquidity Management Requirements for ART and EMT Issuers

On 27 June 2025, the European Commission adopted a Delegated Regulation supplementing the Markets in Crypto-Assets Regulation (MiCA, EU 2023/1114). The act introduces minimum liquidity management policy requirements for issuers of asset-referenced tokens (ARTs) and e-money tokens (EMTs).

Scope and Purpose of the New Regulation

The new rules define:

• the scope of entities covered,
• key obligations on liquidity risk monitoring,
• stress testing and contingency planning,
• segregation of reserves,
• and early warning mechanisms for liquidity management.

The goal is to ensure that reserve assets have a resilient liquidity profile, enabling issuers to meet redemption requests at any time – even under stress conditions – without disrupting normal operations.

Who Must Comply?

The obligation to implement a formal liquidity management policy applies mainly to:

• issuers of significant asset-referenced tokens,
• e-money institutions issuing significant e-money tokens (as defined under MiCA).

Under Articles 45(3) and 58(1) MiCA, such issuers must establish and maintain procedures to assess and monitor liquidity needs so they can meet redemption requests promptly. National regulators may also extend these requirements to non-significant issuers (pursuant to Articles 35(4) and 58(2) MiCA).

Notably, for significant ARTs, at least 60% of reserve assets must consist of deposits in each official currency referenced by the token.

Core Elements of the Liquidity Policy

The Delegated Regulation sets out in detail the minimum content of a liquidity management policy, requiring issuers to implement comprehensive procedures and control mechanisms. The policy should cover at least the following areas:

1. Procedures for Identifying, Measuring, and Monitoring Liquidity Risk

Issuers are required to:

• develop and implement procedures for the systematic identification of potential liquidity risks,
• apply both quantitative and qualitative methods to measure the level of liquidity risk across different time horizons,
• continuously monitor all factors affecting solvency and the ability to meet redemption requests, including market trends, demand dynamics, and the condition of reserve assets,
• produce regular internal reports to ensure that management is kept fully informed of the state of reserves and related risks.

2. Internal Limits and Early Warning Indicators

The liquidity policy should define:

• operational limits specifying the acceptable level of divergence between the value of tokens in circulation and the market value of reserve assets,
• at least two early warning indicators that must be continuously tracked, such as:
  • deviations between the market value of circulating tokens and the market value of backing reserve assets,
  • volatility of reference assets relative to the reserve’s value,
• escalation procedures that ensure a swift and effective response when thresholds are exceeded.

These indicators enable early detection of risks to stability, such as a loss of parity between the token and its underlying assets (so-called de-pegging events).

3. Techniques to Maintain Token and Reserve Value Stability

Issuers must employ:

• tools ensuring full alignment between the value of tokens in circulation and the value of reserve assets,
• mechanisms allowing for the immediate correction of deviations once identified,
• processes guaranteeing transparency and real-time accuracy of reserve data.

4. Independent Liquidity Risk Management Function

The policy must provide for:

• a clear segregation of duties across organizational units,
• the appointment of individuals or a committee responsible for ongoing supervision of liquidity risk,
• an independent internal reporting system free from conflicts of interest,
• mechanisms to ensure that risk assessments and alerts are escalated directly to senior management.

Stress Testing: A Cornerstone of the New Standards

Regular stress testing is a key element of the new rules, designed to assess the resilience of liquidity reserves.

Issuers of significant tokens are required to conduct such tests at least once a month, in line with MiCA technical standards on frequency and scenario design. Tests must cover severe but plausible scenarios, including:

• mass redemption requests,
• sudden declines in the value of reserve assets,
• other major market shocks.

In addition, reverse stress testing is required – analyzing the conditions that would cause the reserve’s liquidity to collapse and identifying the critical breaking point of the buffer’s resilience.

Test results cannot be ignored. Issuers must use them to review strategies, internal policies, and risk limits, and to implement necessary remedial measures. All results and corrective actions must be documented and made available to supervisory authorities.

Contingency Liquidity Planning

The new regulations place strong emphasis on the requirement for issuers to have a liquidity contingency policy – a dedicated plan for managing liquidity crises.

Such a plan should include:

• diversified liquidity sources, such as credit lines or cash reserves held across multiple institutions, to be accessed in the event of sudden outflows,
• clearly defined roles and decision-making responsibilities, specifying who is responsible for initiating emergency measures and in what sequence,
• internal thresholds and escalation procedures, which trigger corrective actions when predefined indicators are breached.

The plan must also provide for a continuous market monitoring system, based on internal limits, enabling the issuer to detect early warning signs and act before liquidity is depleted. With these mechanisms in place, issuers can ensure timely responses under both normal and stressed conditions.

Reserve Management and Segregation

The new rules place significant emphasis on how issuers manage the reserve assets backing their tokens. The key requirements include:

• Segregation and transparency of reserves – reserve assets must be legally and operationally separated from the issuer’s own funds. This protects token holders from the risk of reserves being used for other purposes and ensures their safeguarding in the event of the issuer’s insolvency.
• Separate liquidity policy for each token – if an issuer offers more than one stablecoin, it must maintain a distinct liquidity policy and procedures for each issuance.
• Consideration of the characteristics of reference assets – each policy should be tailored to the specific nature of the reference assets and the correlations that affect the stability of the given token.
• Exclusion from the issuer’s general liquidity policies – the liquidity policy for a stablecoin cannot be part of the issuer’s overall liquidity framework for other business activities; it must be a standalone document.

This approach ensures greater transparency and prevents liquidity risks from different projects from becoming intertwined. It also enables supervisory authorities to assess the risk profile of each token individually.

Market Impact

The new rules will enter into force 20 days after their publication in the EU Official Journal, significantly raising prudential standards in the stablecoin sector.

For Issuers

ART and EMT issuers will be required to implement comprehensive liquidity risk management frameworks, including: specialized control procedures, monitoring and reporting systems, regular stress testing and contingency planning. For many issuers, this will involve investments in new analytical tools as well as additional legal and compliance expertise.

For Investors

Token holders will gain stronger protection of their funds and greater certainty of redemption, even in crisis conditions. The new requirements reduce the risk of issuer illiquidity or payout suspension, thereby increasing confidence in stablecoins as a reliable means of payment.

For Financial Institutions and FinTechs

These entities will face standards approaching those applied to banks, raising the regulatory bar. On the other hand, accepting MiCA – compliant stablecoins will become safer, as it will be clear that tokens are backed by well-managed reserve assets. This will pave the way for easier integration of stablecoins into the traditional financial system.

Stay Ahead of MiCA Developments

Do you want to stay up to date with the latest EU regulatory changes for crypto-assets? Join our newsletter to receive expert insights straight to your inbox.