March 31, 2025. An EU user logs in to their Coinbase Europe account to top up some USDT before a transfer. The option is gone. Not suspended — removed. Coinbase Europe had delisted USDT weeks earlier to comply with MiCA, and every other major regulated exchange in the EEA followed suit that day: Binance removed all USDT spot pairs, Kraken fully disabled the asset, and Crypto.com had already halted trading months before.
Across the Atlantic, a US user in early 2026 checks whether their USDC position on a centralized platform still earns the 4.5% annual yield product they had been holding. They receive a notice: yield products linked to payment stablecoins are under regulatory review ahead of the GENIUS Act's compliance window.
Same asset class — dollar stablecoins. Two completely different regulatory realities.
This article maps the practical answer to the question both users are really asking: which stablecoins can I actually hold and use in my region, and what restrictions apply? For the legal mechanics behind each law, see MiCA, GENIUS Act, and What They Mean and What a Stablecoin Actually Is: Reserves, Redemption, and Issuer Risk — this capstone focuses on outcomes.
MiCA's Stablecoin Taxonomy: EMTs and ARTs
MiCA — the EU's Markets in Crypto-Assets Regulation — created two categories for stablecoins.
E-money tokens (EMTs) are stablecoins pegged to a single fiat currency. USDC and EURC (Circle's euro-denominated stablecoin) are both EMTs. Every EMT must be issued by an EU-authorized Electronic Money Institution (EMI) — a specific EU license type. Circle obtained an EMI license from France's ACPR (Autorité de Contrôle Prudentiel et de Résolution) on July 1, 2024, making it the first global stablecoin issuer to achieve MiCA compliance and authorizing USDC and EURC for distribution across all 27 EU member states.
Asset-referenced tokens (ARTs) cover stablecoins backed by baskets of assets or non-fiat references. They face stricter capital and reserve requirements than EMTs.
From March 31, 2025, issuers without EU authorization could no longer have their tokens offered to the public or listed on MiCA-regulated venues in the European Economic Area (EEA). As of late 2025, fewer than 15 stablecoins hold active MiCA authorization, all as EMTs. The most significant are USDC and EURC; smaller euro tokens — EURI, EURCV, EUROe, EURQ, EURS — also qualify.
For what full enforcement looks like in practice — licensed exchange counts, issuer registry, and CASP authorization — see MiCA in Year Two: What Full Enforcement Looks Like for Users.
USDT in the EU: Delisted on Exchanges, Legal in Self-Custody
Tether chose not to seek MiCA authorization for USDT. That decision had immediate, concrete consequences.
The delistings on March 31, 2025 were mandatory compliance actions across every regulated EEA exchange:
- Coinbase Europe: delisted USDT effective March 31 (announced December 2024)
- Crypto.com: halted USDT by January 31, with a March 31 conversion deadline
- Binance EEA: removed all USDT spot pairs on March 31 (derivatives remained accessible due to a regulatory nuance)
- Kraken: moved USDT to sell-only on March 24, fully disabled by March 31
But here is the distinction EU users need to understand. ESMA — the European Securities and Markets Authority — explicitly clarified that "custody and transfer services do not in themselves constitute an offering to the public." That ruling means:
EU residents can hold, transfer, receive, and withdraw USDT in self-custody without violating MiCA. The restriction applies only at the platform layer — buying and trading on regulated EEA exchanges.
MiCA-authorized EMT issuers must also redeem tokens at par on demand — a statutory legal right for USDC and EURC holders. USDT holders in self-custody rely on Tether's commercial policy, not a legal mandate.
The GENIUS Act: America's Payment Stablecoin Framework
The United States took a different approach. The GENIUS Act was signed into law on July 18, 2025 — after passing the Senate 68–30 on June 17 and the House 308–122 on July 17 — becoming the first federal statute to create a comprehensive regulatory framework for fiat-backed stablecoins.
The GENIUS Act defines a payment stablecoin as a digital asset used for payment or settlement where the issuer maintains stable value through conversion or redemption rights — explicitly excluding bank deposits, securities, and commodities.
Three permitted issuer pathways exist:
- Subsidiaries of insured depository institutions supervised by federal banking regulators
- Federally qualified issuers: nonbanks or uninsured national banks approved by the OCC (Office of the Comptroller of the Currency)
- State-qualified issuers, only where the state's regime is certified as "substantially similar" to federal requirements
A $10 billion threshold separates regulatory tiers: issuers with outstanding supply above $10B must obtain primary federal supervision (OCC and/or Federal Reserve); those below may operate under a certified state regime.
Reserves must be maintained at least 1:1 in eligible low-risk assets — USD cash, short-term Treasuries, repos — with monthly public disclosures mandatory and rehypothecation of reserve assets prohibited. Digital asset service providers have until July 18, 2028 to comply with restrictions on supported stablecoins.
The GENIUS Act also explicitly carves out "self-custodial wallets and immutable software interfaces" from its regulatory scope — a direct parallel to ESMA's MiCA clarification.
The US Stablecoin Framework in 2026 covers how OCC, FDIC, and Treasury rules translate the statute into issuer obligations.
Which Stablecoins Qualify in the US
The GENIUS Act compliance window closes in 2028, so the field is still in motion — but the principal names are clear.
USDC (Circle): The natural incumbent. Circle's reserve structure, monthly attestations, and OCC-pathway planning align with the law's requirements; full compliance is targeted ahead of the January 2027 enforcement date.
USAT (USA₮): Tether's US-specific stablecoin, launched January 27, 2026, and purpose-built for the GENIUS Act. It is issued by Anchorage Digital Bank N.A. — an OCC-chartered, federally regulated digital asset bank — with Cantor Fitzgerald as designated reserve custodian and preferred primary dealer. Phase 1 launched on Bybit, Crypto.com, Kraken, OKX, and MoonPay. USAT is a separate product from offshore USDT. Tether has confirmed that USDT will continue operating globally under its existing offshore structure, with USAT serving the US-regulated market.
PYUSD (PayPal) and RLUSD (Ripple): Both positioned as GENIUS Act-aligned, with issuers holding banking licenses or OCC trust charters.
For an issuer-by-issuer breakdown of what "regulated" actually protects for holders, see USDC, USAT, PYUSD, RLUSD — What 'Regulated' Actually Buys You.
EU vs US: A Practical Side-by-Side
The two regimes share the same goal — consumer protection through reserve requirements and issuer accountability — but they regulate different layers of the system.
EU under MiCA:
- On regulated exchanges: only MiCA-authorized EMTs are tradeable. In practice: USDC and EURC are your dollar and euro stablecoin options; USDT is unavailable for purchase or trading on any licensed EEA platform.
- In self-custody: any stablecoin you hold — including USDT — is fully lawful to hold, send, and receive. The restriction is purely at the platform layer.
- Redemption: MiCA EMT holders have a statutory right to redeem at par from the issuer.
US under the GENIUS Act:
- On regulated platforms: before July 2028, platforms may still offer non-compliant stablecoins. After the deadline, they will likely align their supported stablecoin lists with GENIUS Act-approved issuers — potentially producing a USDT situation similar to the EU's March 2025 experience.
- In self-custody: self-custodial wallets are explicitly outside the GENIUS Act's scope.
- Redemption: payment stablecoin holders receive statutory redemption rights and bankruptcy priority claims on reserves. USDT holders in self-custody in the US, like their EU counterparts, rely on Tether's commercial commitment alone.
The big structural asymmetry: MiCA targets which stablecoins can be traded on regulated platforms. The GENIUS Act targets which entities can issue and distribute payment stablecoins. Self-custody is carved out in both.
What About Yield?
The GENIUS Act's no-yield prohibition is one of its most consequential rules for US holders. The statute bars payment stablecoin issuers from offering or paying holders "any form of interest or yield (whether in cash, tokens, or other consideration) solely in connection with the holding, use, or retention of the stablecoin."
This is an issuer-level prohibition, not a user-level one. In practice:
- USDC and USAT will not pay interest to holders directly from the issuer.
- DeFi yield on USDC — earned through a lending protocol or liquidity pool — comes from the protocol's own strategy, not the issuer. That path remains open.
- Some centralized platform yield products structured as "earn on your stablecoin" may require restructuring before the July 2028 deadline if they depend on the issuer passing interest through.
MiCA does not contain a comparable no-yield prohibition for EMTs. EU holders of USDC or EURC can earn yield on those assets through DeFi or compliant product structures without the same issuer-level constraint.
What You Can Hold in Self-Custody, Wherever You Are
Neither MiCA nor the GENIUS Act restricts self-custody. ESMA confirmed that custody and transfer services do not constitute "offering to the public." The GENIUS Act explicitly carves out self-custodial wallets from its scope.
A Zelcore wallet holding USDC, EURC, USDT, USAT, or any other on-chain stablecoin does so regardless of your physical location. The regulatory restrictions activate when you interact with a regulated exchange or payment provider in a given jurisdiction — not when you hold assets on-chain.
Practical workflows:
For EU users: Acquire USDC or EURC on a MiCA-licensed exchange, then withdraw to self-custody for on-chain use and transfers. USDT can be held and transacted from self-custody; it cannot be purchased on any EEA-regulated exchange.
For US users: Building habits around USDC or USAT now future-proofs against the 2027–2028 compliance window without sacrificing self-custody flexibility. USDT remains holdable in self-custody through the transition period and beyond.
Cross-border scenario: Your on-chain holdings do not change when you cross a border. Jurisdiction rules activate when you interact with a regulated service provider — exchange, brokerage, or payment app — in that jurisdiction.
Key Takeaways
- EU users: USDT cannot be purchased or traded on any licensed EEA exchange as of March 31, 2025. USDC and EURC are the MiCA-authorized options on regulated platforms. Holding USDT in self-custody remains fully lawful under ESMA's clarification.
- US users: The GENIUS Act (signed July 18, 2025) introduces a no-yield prohibition at the issuer level — payment stablecoins cannot pay interest to holders directly. DeFi yield is unaffected. Platform compliance is required by July 18, 2028.
- USAT is not USDT: Tether's US-compliant stablecoin USAT, launched January 27, 2026 and issued by an OCC-chartered bank, is purpose-built for the GENIUS Act — a separate product from the offshore USDT that continues to operate globally.
- Both regimes protect self-custody: ESMA and the GENIUS Act both explicitly exclude self-custodial wallets from their scope. What you hold on-chain in a self-custody wallet is yours, in either jurisdiction.
- Redemption rights matter: MiCA EMT holders and GENIUS Act payment stablecoin holders both carry statutory redemption rights. USDT holders in either region rely on Tether's commercial policy — a meaningful counterparty-risk distinction when choosing what to hold.
Sources
- https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1114
- https://vaultody.com/blog/296-what-mica-means-for-tether-usdt-delistings-custody-and-the-future-of-stablecoins-in-the-eea
- https://www.circle.com/pressroom/circle-is-first-global-stablecoin-issuer-to-comply-with-mica-eus-landmark-crypto-law
- https://www.getivy.io/stablecoins/mica-regulated-stablecoins
- https://www.whitehouse.gov/fact-sheets/2025/07/fact-sheet-president-donald-j-trump-signs-genius-act-into-law/
- https://www.gtlaw.com/en/insights/2025/7/genius-act-enacted-establishing-a-regulatory-framework-for-payment-stablecoins-issued-or-sold-in-the-united-states
- https://www.mayerbrown.com/en/insights/publications/2025/07/genius-act-signed-into-law-us-enacts-federal-stablecoin-legislation
- https://tether.io/news/tether-announces-the-launch-of-usat-the-federally-regulated-dollar-backed-stablecoin-made-in-america/
