What MiCA Article 22 actually means for your stablecoin treasury
MiCA's Article 22 sets reserve, audit, and redemption requirements for stablecoin issuers operating in the EU. For corporates holding stablecoins as treasury, the second-order effects are larger than the issuers' compliance costs.
Placeholder body. The published version will walk through Article 22 in plain English, explain the corporate-treasury implications most counsel miss, and recommend three documents to add to the treasury policy.
What Article 22 says
Article 22 of MiCA imposes 1:1 backing, daily reserve disclosure, and same-day redemption obligations on issuers of asset-referenced tokens. For a corporate holding USDC or EURC as part of treasury, this is not a direct obligation — but it changes the risk profile of the holding in ways most policies do not address.
The second-order effects
- 01An issuer's reserve composition is now publicly disclosed. Treasury policy should specify acceptable reserve compositions.
- 02Same-day redemption is contractual, not best-effort. This shifts the holding from credit-like to deposit-like for liquidity planning.
- 03Cross-jurisdictional holdings (US-issued USDC held in an EU subsidiary) create regulatory ambiguity not yet resolved.
What to add to your treasury policy
Three concrete additions: a stablecoin reserve composition standard, a counterparty concentration limit, and a redemption-timing assumption with documented stress test.
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