MiCA explainer

Non-MiCA Stablecoins 26.10.2026: Baltic Watchlist

Explainer and Watchlist Publication: No new dated events in the region in the last 24 hours or week, so we're examining ESMA's 8 October opinion on the wind-down of unauthorised stablecoins in the Baltics and Northern Europe.

Toms Ābeltiņš

26 October 20266 min read

No new dated events in our segment in the Baltics and Northern Europe in the last 24 hours, so we're offering an explainer: On 8 October, ESMA called on MiCA-licensed CASPs to cease services related to unauthorised stablecoins (ART/EMT) by approximately 8 January 2027. This has implications for regional exchanges and cards.

Monday, 26 October 2026. This is an Explainer and Watchlist publication, not a classic daily review. In the last 24 hours, there have been no new, clearly dated significant events in our segment - crypto exchanges and CASPs, hardware wallets, crypto cards, and tax tools serving the Baltics (LV, LT, EE) and Northern Europe (FI, SE, NO, DK). Furthermore, no new CASP authorisations or other segment events with a definitive date have been registered in the region in the last week (20-26 October). Therefore, today we're opting for an honest format: we're taking an in-depth look at an ongoing regulatory topic directly affecting market participants in the region - the European Securities and Markets Authority's (ESMA) 8 October opinion on the wind-down of unauthorised stablecoin services and its approximate 8 January 2027 deadline. Older and ongoing stories are presented as context, not fresh news.

What Happened: ESMA's 8 October Opinion

On 8 October 2026, ESMA published a supervisory opinion outlining to national competent supervisors that MiCA-licensed Crypto-Asset Service Providers (CASPs) should cease services related to unauthorised stablecoins - specifically, asset-referenced tokens (ARTs) and e-money tokens (EMTs) that do not have MiCA authorisation. The opinion states that firms should resolve remaining client positions in such assets "as soon as possible and no later than three months" after the opinion's publication. Counting from 8 October, this implies an approximate deadline around 8 January 2027.

It's important to clarify two points that are often oversimplified. Firstly, ESMA's opinion provides supervisory guidelines, not directly applicable law; its practical implementation is at the discretion of national supervisors, and each authority decides how broad "exit" services it will permit. Secondly, the opinion does not name specific tokens or issuers; it applies to any ART or EMT without MiCA authorisation, not to any named stablecoin.

In practice, supervisors may allow strictly limited exit services: liquidation, conversion, withdrawal, transfer, or custody of existing positions. The acquisition of new such assets, their promotion, and their continued availability for trading are prohibited. As each national supervisor decides individually, the actual transition window available to clients in different countries may vary and be shorter than the full three months.

What This Means for Our Segment

This topic is directly relevant to at least two of our four segment categories. The first is crypto exchanges and CASPs serving the Baltics and Northern Europe: those offering non-MiCA stablecoins will likely gradually remove such trading pairs for European clients in the coming months or shift them to MiCA-authorised EMTs. The second is crypto cards, some of which rely on stablecoins for backend settlements; issuers and their partner banks must ensure that settlement assets comply with MiCA requirements.

For regional users, the practical impact may manifest as the disappearance of a specific stablecoin trading pair, a transition to a MiCA-authorised alternative, or a call to convert balances by a specified deadline. This is not a new surprise - several large platforms had already limited the availability of certain stablecoins to European clients before this opinion - but ESMA's opinion for the first time sets a relatively concrete timeframe for the entire EU CASP industry.

Baltic and Nordic Perspective: What National Supervisors Are Doing

Currently, national supervisors in our region - Latvijas Banka, Lietuvos bankas, Estonia's Finantsinspektsioon, Finland's Finanssivalvonta (FIN-FSA), Sweden's Finansinspektionen, and Norway's and Denmark's Finanstilsynet - have not published separate, clearly dated implementation announcements directly regarding this ESMA opinion; at least, none are publicly available at the time of this publication. This in itself is a watchlist item: from an EU-wide opinion to national implementation usually takes several weeks, and the first indications are likely to appear in the news sections of supervisors' websites or in industry letters.

For comparison, outside our region, the first signs of implementation are already visible: Italy's supervisor CONSOB formally supported ESMA's position on 16 October. We mention this only as an indication of how the process might unfold at the national level, not as a regional event.

Context: Other Segment Events (Reminder, Not Fresh News)

These points are not news from the last 24 hours; we include them only for background, with precise previous dates.

In the hardware wallet segment, the Coldcard (Coinkite) related topic continued in early October. On 11 October, Coldcard's official X account was hacked, and attackers published a fake announcement about a "critical firmware vulnerability," urging users to move funds via a phishing site; the post was later deleted. The risk primarily affected those who entered their seed phrase on the fake site. This event, in turn, referred to an older, more serious Coldcard incident - a weak randomness (entropy) bug in a 2021 firmware build, which led to a significant amount of Bitcoin being stolen from affected seeds starting from 30 July. Both events are tied to specific Coldcard models and firmware versions, not to any regional platform, and remain an ongoing story.

On the licensing side, on 23 October, payment company Solidgate announced that the Cypriot supervisor CySEC had granted it a MiCA CASP authorisation with stablecoin custody, fiat-stablecoin exchange, and settlement scope, usable across the entire EEA. This is not a Baltic or Nordic event, but it illustrates the same direction - regulatory compliant stablecoin infrastructure - which is the other side of today's main topic.

Watchlist (Ongoing Stories)

National Implementation: We are monitoring when Latvijas Banka, Lietuvos bankas, Finantsinspektsioon, FIN-FSA, Finansinspektionen, and Finanstilsynet (NO/DK) will publish specific guidance on the application of ESMA's 8 October opinion and whether they will set different exit windows.

Deadline ~8 January 2027: We are monitoring whether ESMA or national supervisors will clarify exactly which date is considered final, as the three-month window is counted from publication and interpreted slightly differently in various sources.

Regional Exchange Reaction: We are observing whether Baltic and Nordic CASPs will announce the removal of specific stablecoin pairs or a transition to MiCA-authorised EMTs.

Coldcard Account Security: We are monitoring whether the X platform or Coinkite will provide additional information about the 11 October account hack.

Crypto Cards: We are observing whether card issuers active in the region will comment on the MiCA compliance of stablecoin settlements.

Summary for Market Participants

For regional exchanges and CASPs: It is advisable to map now which stablecoins in your offering are MiCA-authorised EMTs and which are not, and to prepare client communication about a possible exit window, without waiting for a separate letter from the national supervisor.

For crypto card users and issuers: It is worth checking what settlement assets a particular product relies on, as the use of non-MiCA stablecoins in the background may be restricted in the coming months.

For private users: If you hold stablecoins on an exchange operating in the region, follow the platform's announcements regarding possible conversion or withdrawal; there is no cause for panic, but it is worth not missing the deadlines that each platform will announce separately.

For everyone: This is an explainer, not a news article. The only clearly dated EU-wide event is ESMA's 8 October opinion; the deadline around 8 January 2027 is derived from the three-month window and may be clarified. National implementation in the Baltics and Nordics is not yet publicly datable at this time, and that is precisely what we will be following in future publications.

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