Helsinki

The Helsinki DARTE session took place on November 19th, 2025, at the offices of Nordic Law, in collaboration with the European Commission, Project Catalyst, Bybit EU, and Nordic Law. This edition focused on cross-border compliance challenges and strategic frictions in the implementation of MiCAR, continuing DARTE’s mission to convene expert dialogue across regulation, market infrastructure, and financial innovation.

The roundtable gathered regulators, legal practitioners, and digital asset infrastructure providers to assess the evolving legal and operational terrain around stablecoins, licensing regimes, and reserve requirements. The session opened with keynote remarks by Mazurka Zeng, Managing Director of Bybit EU, who framed stablecoins as the long-missing bridge between crypto ecosystems and practical financial utility. She highlighted how programmable finance, institutional engagement, and the emergence of regulatory clarity, particularly through MiCAR, are aligning to make "Finance 3.0" viable, accessible, and scalable. Drawing on global examples, she argued that stablecoins are not just instruments of price stability, but critical infrastructure for real-world settlement, transparency, and financial inclusion. Her remarks called attention to the need for regulatory cooperation, liquidity corridor development, and incentive alignment across the ecosystem to ensure stablecoins can deliver on their promise as foundational tools for modern finance.

Max Atallah (Nordic Law) initiated the technical discussions with a legal breakdown of multi-jurisdictional stablecoin issuance under MiCAR, emphasizing that the framework not only permits but anticipates cross-border models, even as institutional hesitancy and supervisory fragmentation continue to stall implementation. Simon Seiter (AllUnity) followed with an analysis of the dual licensing dilemma facing CASPs under MiCAR and PSD2, arguing for the legal and practical separation between blockchain-native transfer services and traditional payment accounts. Finally, Magnus Jones (Nordic Blockchain Association) led a strategic discussion on reserve allocation constraints and concentration risk, noting the unresolved tensions between liquidity mandates, custodial dependency, and cross-border operability in MiCAR’s evolving RTS.

The Helsinki edition reaffirmed DARTE’s role as a trusted venue for shaping Europe’s digital asset regulatory landscape through grounded, multi-stakeholder dialogue. As financial infrastructure becomes increasingly tokenized, the session underscored the importance of interpretive clarity, institutional alignment, and risk-sensitive policy tools to ensure regulatory resilience without stifling innovation.

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Multi-Jurisdictional Stablecoin Issuance

The session examined the legal and operational feasibility of issuing stablecoins across multiple jurisdictions under MiCAR. While the text of MiCAR particularly Recital 54 and Articles 54–56, anticipates and accommodates such structures, participants discussed how diverging interpretations by national authorities and political resistance from institutions like the ECB have created legal uncertainty. This ambiguity leads to fragmented supervision, regulatory paralysis, and competitive disadvantages for compliant issuers. The group emphasized the need to distinguish between legal permissibility and supervisory hesitancy, stressing that inconsistent enforcement undermines market confidence and the EU’s ability to foster innovation in tokenized finance.

Call to Actions

Develop a joint interpretive note explaining why MiCAR already permits multi‑jurisdictional EMT issuance, providing immediate clarity without waiting for formal EU guidance.
Create a neutral EU Stablecoin Association to coordinate best practices, promote supervisory convergence, and serve as a single point of engagement for EU institutions.
Establish shared operational standards for reserve management and redemption processes to reduce supervisory hesitation and strengthen consumer protection across jurisdictions

Dual Licensing Requirements (MiCAR & PSD)

The discussion addressed widespread confusion over whether CASPs facilitating EMT transfers must obtain both MiCAR authorization and PSD2 licensing. Participants noted that this uncertainty stems from mischaracterizing blockchain transfers as “payment services,” despite MiCAR already regulating on‑chain transfer services and the travel rule governing informational requirements. The session clarified the functional distinctions between a wallet and a payment account, and between an on‑chain transfer and a PSD2 credit transfer or remittance. Participants warned that forcing dual licensing where it is not legally required risks unnecessary supervisory fragmentation, steep compliance costs, and a chilling effect on market entry. Several contributions emphasized that regulatory clarification is urgently needed to prevent CASPs from being pushed toward duplicative and, in many cases impractical, licensing pathways.

Call to Actions

Issue a joint interpretive note clarifying that pure on‑chain EMT transfers fall under MiCAR, not PSD2, and defining clear guardrails for when PSD2 applies.
Encourage supervisors to apply proportionate convergence, distinguishing wallets from payment accounts and blockchain transfers from fiat remittances to avoid unnecessary dual licensing.
Initiate a coordinated clarification for PSD3/PSR, affirming that MiCAR governs on‑chain transfers while PSD applies only where an actual PSD2 payment service is provided.

The Reserves Concentration Crunch

The session explored whether MiCAR’s reserve, liquidity, and concentration rules may inadvertently increase systemic risk by funneling stablecoin reserves into a limited range of high‑quality liquid financial instruments (HQLFIs) and a handful of large banks and custodians. Participants warned that inflexible categorical lists, strict concentration caps, and inconsistent national interpretations risk creating new single‑points‑of‑failure, weakening redemption resilience, and raising barriers to entry. The debate emphasized the need for a proportionate, risk‑sensitive framework that balances liquidity assurance with operational feasibility, competitive neutrality, and realistic stress‑scenario performance.

Call to Actions

Support a calibrated, risk‑sensitive RTS framework that maintains core HQLFI requirements while allowing a supervisory‑approved secondary list subject to haircuts and objective liquidity metrics.
Make liquidity stress testing the central criterion for reserve adequacy, enabling flexibility where issuers can empirically demonstrate convertibility under stress.
Develop proportionate concentration thresholds that trigger enhanced oversight rather than rigid prohibitions, allowing diversified custody models and preventing systemic over‑concentration.