Your MiCAR Checklist: 3 Steps to Take After the New EBA Standards
This article breaks down the European Banking Authority’s September 2025 technical standards for stablecoins into three practical steps: strengthen your audit trails to capture every action, meticulously document and verify reserve assets, and rigorously stress-test your systems against worst-case scenarios. Together, these measures help stablecoin issuers move beyond basic compliance toward resilience and long-term trust under MiCAR’s evolving regulatory framework.
Your MiCAR Checklist: 3 Steps to Take After the New EBA Standards
Have you ever stared at a 100-page regulatory document and felt a slow, creeping sense of dread? Like you’ve been asked to assemble a spaceship with instructions written in ancient hieroglyphs? That’s how many in the Web3 space felt when the European Banking Authority (EBA) dropped its latest batch of technical standards for stablecoins under MiCAR. For Web3 founders and compliance teams, this isn't just another piece of paper; it’s a detailed operational roadmap. But it doesn't have to be overwhelming. In this post, we’ll break down exactly what you need to focus on so you can build with confidence and stay on the right side of the rules.
1. Fortify Your Audit Trails
First things first: data. The new standards place a heavy emphasis on your ability to track everything. An audit trail is a chronological record of all activities within a system. Under MiCAR, it’s your best friend for proving your operations are sound. The EBA now requires issuers of e-money tokens (the regulatory term for most stablecoins) to maintain meticulous, time-stamped records for everything from asset-reserve management to customer complaints.
Think of it like a bakery’s ledger. You wouldn't just count the bread at the end of the day; you'd track the flour coming in, the loaves baked, and every single sale. According to the European Banking Authority (EBA) in its September 2025 technical standards, these trails must be secure, tamper-evident, and readily available for regulators to inspect (link). To comply, start by reviewing your current logging systems. Are they comprehensive? Do they capture every transaction, internal transfer, and governance decision? If not, now is the time to partner with a compliance tech provider or dedicate engineering resources to build more robust internal dashboards.
2. Recalculate and Document Your Reserves
The heart of any stablecoin is its reserve. This is the pool of real-world assets that backs the value of the tokens you issue. The new standards get incredibly specific about how you must manage and document these assets. It's no longer enough to just hold "enough" capital; you must prove it with a new level of granularity.
For example, the rules now detail the specific methodologies for calculating your capital requirements and how to document any off-chain assets, like bonds or cash held at a bank. A recent analysis by financial law firm Simmons & Simmons (2025) highlights that issuers must have clear, legally enforceable claims on these assets and document them impeccably (link). Your first step should be an internal audit. Go through your reserve assets one by one and create a corresponding documentation folder for each. Does each asset have a clear chain of custody and proof of ownership? If you find gaps, close them immediately. This isn't just a compliance exercise; it’s fundamental to building trust with your users.
3. Stress-Test Your New Reality
Finally, it’s not enough to have these systems in place. You have to prove they work under pressure. The EBA standards imply a need for rigorous stress testing. This involves simulating extreme market scenarios—like a bank run or a sudden crash in the value of a reserve asset—to see if your recovery and resolution plans hold up.
While the rules don't use the words "Allie Brosh illustrating a dumpster fire," they paint a clear picture of the chaos they want you to avoid. Regulators want to know: what’s your plan for an orderly wind-down if things go south? Start by running tabletop exercises with your team. What happens if a custodian freezes your funds? What if a large holder tries to redeem all at once? Document these scenarios and your step-by-step responses. This will not only prepare you for the worst but also reveal weaknesses in your current operations that you can fix before they become real problems.
Your Path Forward
In short, the new MiCAR technical standards ask for three things: radical transparency in your data, meticulous documentation of your assets, and a battle-tested plan for when things go wrong. By fortifying your audit trails, performing a deep dive on your reserve documentation, and actively stress-testing your systems, you can move beyond compliance and build a more resilient, trustworthy platform. The era of "move fast and break things" is giving way to "build smart and make it last."
I’d love to hear how your team is approaching these new requirements—share any insights or challenges in the comments below!
References
- European Banking Authority. (2025, September). Final Report on Draft Regulatory Technical Standards under MiCAR. EBA. [Link to be added when available]
- Simmons & Simmons. (2025, September). Analysis of New EBA Technical Standards for E-Money Token Issuers. [Link to be added when available]