
Briefing
The European Commission has published the final Regulatory Technical Standards (RTS) specifying the minimum contents of the liquidity management policy for issuers of Asset-Referenced Tokens (ARTs) and E-Money Tokens (EMTs), effectively operationalizing a core pillar of the Markets in Crypto-Assets (MiCA) regulation. This action mandates that regulated entities establish comprehensive procedures for identifying, measuring, and managing liquidity risk, alongside detailed contingency plans and mitigation tools, thereby integrating stablecoin-like assets into a robust financial stability framework. The Delegated Regulation officially enters into force on October 23, 2025 , initiating the final countdown for compliance system integration.

Context
Prior to the finalization of these Level 2 measures, the MiCA framework established the high-level requirement for ART and EMT issuers to maintain sufficient liquid reserves and implement redemption plans, but the specific, actionable compliance architecture remained ambiguous. This regulatory gap created uncertainty for firms regarding the necessary granularity of their risk models, the required governance for reserve assets, and the precise methodology for calculating and aggregating crypto exposure values, which is essential for ensuring systemic financial stability across the bloc.

Analysis
This final RTS necessitates a fundamental update to the operational risk architecture of all ART and EMT issuers. Firms must now integrate detailed liquidity stress testing into their enterprise risk management systems, modeling various market shock scenarios to prove the resilience of their reserve assets and redemption mechanisms. The mandate for a contingency policy requires the establishment of clear governance and mitigation tools, fundamentally altering the product structuring and risk reporting workflows.
Compliance teams must also ensure their policies align with the specified requirements for the minimum amount of deposits in each official currency referenced, which directly impacts treasury and custody operations. This systemic overhaul moves the industry from a principle-based obligation to a prescriptive, auditable compliance standard.

Parameters
- Entry Into Force Date ∞ October 23, 2025 (The date the Delegated Regulation officially becomes binding law in the EU).
- MiCA Article ∞ Article 36(4) (The specific MiCA provision mandating the liquidity management policy).
- Key Requirement ∞ Liquidity Stress Testing (A mandatory component of the new liquidity management policy and procedures).

Outlook
The publication of these standards signals the final phase of MiCA implementation for stablecoin-like assets, shifting the focus from policy drafting to mandatory operational integration across the EU. This prescriptive approach to reserve liquidity and stress testing is likely to set a global precedent, influencing how other major jurisdictions, particularly the US and UK, structure their own stablecoin reserve requirements and financial stability controls. Firms that achieve early, robust compliance will gain a competitive advantage by securing the “European passport” and demonstrating a higher standard of institutional-grade risk management to global counterparties.
