ART vs EMT: How MiCA Classifies Crypto-Assets and the Software Each Needs
ART vs EMT under MiCA explained: asset-referenced tokens, e-money tokens and other crypto-assets, their obligations, supervision and the software token issuers need to build.
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Before you write a line of code or file an application, MiCA forces one decision: what kind of crypto-asset are you dealing with? The EU Markets in Crypto-Assets Regulation (Regulation (EU) 2023/1114) sorts crypto-assets into three groups – asset-referenced tokens (ART), e-money tokens (EMT) and other crypto-assets – and each group carries a different rulebook and a different software burden. This article explains the difference and what issuers must build for each.
It is an explainer, not legal advice. Classification is a legal call for qualified counsel, and the boundary with financial instruments under MiFID II sits outside our scope. For the full build, see our MiCA compliance software development.
The three MiCA token categories
MiCA treats a crypto-asset as a digital representation of value or rights that can be transferred and stored electronically using distributed ledger technology. Within that, three categories decide your obligations:
- Asset-referenced token (ART). References any value or right, or a combination, including one or more official currencies. A token backed by a basket of currencies, commodities or other crypto-assets is an ART.
- E-money token (EMT). References the value of a single official currency. A euro-pegged or dollar-pegged stablecoin is the textbook EMT.
- Other crypto-asset. Anything that is neither an ART nor an EMT, including most utility tokens.
ART vs EMT vs other crypto-asset at a glance
| ART | EMT | Other crypto-asset | |
|---|---|---|---|
| References | A basket of assets, rights or currencies | A single official currency | Neither |
| Typical example | Multi-currency or commodity-backed token | Euro or dollar stablecoin | Utility token |
| Issuer | Authorised issuer or credit institution | Credit or e-money institution | Any legal person, with a white paper |
| Reserve | Reserve of assets | 1:1 reserve, redemption at par | None required by MiCA |
| Supervisor | National authority, EBA if significant | National authority, EBA if significant | National authority |
| Software | Reserve attestation, redemption, disclosure | Reserve, redemption at par, reporting | White paper tooling, marketing compliance |
Asset-referenced tokens (ART)
An ART issuer needs authorisation and an approved crypto-asset white paper before offering the token to the public. The core obligations are about backing the token and letting holders get their money out.
- Issuer authorisation and an approved white paper
- A reserve of assets, segregated and independently audited, backing the token at all times
- Redemption rights for holders and a clear redemption policy
- Own-funds requirements and ongoing prudential reporting
- Ongoing disclosure of reserve composition and token metrics
E-money tokens (EMT)
An EMT is closer to electronic money. It must generally be issued by a credit institution or an authorised e-money institution, and the headline obligation is redemption at par.
- Issued by a credit institution or e-money institution
- Redemption at par value, at any time, on demand from the holder
- A reserve backing the token one-to-one with the referenced currency
- White paper and ongoing reporting
Significant ART and EMT
If an ART or EMT crosses MiCA’s significance thresholds – measured by holders, market value, transactions and other criteria – it falls under direct supervision by the European Banking Authority, with higher own funds, liquidity-management and interoperability obligations. Build the reserve, stress-testing and reporting systems to that higher bar if you expect scale.
Other crypto-assets and the white paper
Tokens that are neither ART nor EMT still face rules. Offering them to the public, or seeking admission to trading, generally requires a crypto-asset white paper notified to the competent authority, fair and clear marketing communications, and issuer liability for misleading information. There is no reserve obligation, but the disclosure and marketing rules are real.
Why classification comes before code
Get the category wrong and you build the wrong control set, or worse, operate without the right authorisation. Some tokens are not crypto-assets under MiCA at all: financial instruments fall under MiFID II instead, and that boundary needs legal analysis. We do not deploy a token to mainnet without evidence that classification has been reviewed by qualified counsel.
The software each token type needs
Once classification is settled, the build follows from it: reserve management and attestation for ART and EMT, redemption-at-par flows for EMT, white paper notification and versioning for everything, and marketing-communications compliance throughout. Every control writes to one immutable audit trail so disclosure and reporting are a query, not a manual project.
Pharos Production builds MiCA compliance software for token issuers and CASPs. See the token taxonomy in context on the MiCA page, the full compliance checklist and the cost breakdown, or request a gap assessment. We are not a law firm: token classification must be confirmed by qualified counsel.
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An asset-referenced token (ART) references a basket of assets, rights or currencies. An e-money token (EMT) references a single official currency.
EMTs must be issued by a credit or e-money institution and redeemed at par on demand, while ARTs are backed by a reserve of assets. Significant tokens of either type fall under EBA supervision.
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It depends on what it references. A stablecoin pegged to a single official currency, such as the euro or US dollar, is normally an EMT.
A stablecoin backed by a basket of currencies, commodities or other assets is normally an ART. Your counsel confirms the classification before launch.
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An ART or EMT that crosses MiCA significance thresholds, measured by number of holders, market value, transactions and other criteria. Significant tokens are supervised directly by the European Banking Authority and face higher own-funds, liquidity and interoperability obligations.
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Generally yes. Offering an other crypto-asset, including most utility tokens, to the public or seeking admission to trading requires a crypto-asset white paper notified to the competent authority, plus fair and clear marketing communications.
There is no reserve requirement, but the disclosure rules apply.
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Qualified legal counsel, confirmed with the national competent authority. Pharos Production builds the software for the classification your counsel confirms.
We are not a law firm and do not provide legal opinions on token classification or the MiCA and MiFID boundary.
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Genuinely unique and non-fungible tokens are largely outside MiCA, but the substance matters more than the label. NFTs issued in a large series, or that are fungible in practice or behave like financial instruments, can fall in scope.
This is a classification question for counsel.
Role: Founder and CTO, Pharos Production
Focus: Architecture, Web3 products, smart contract security, high-load systems
Experience: 23 years in production delivery
