Excellent DARTE legal note on the much-discussed topic of multi-issuance of stablecoins under MiCA 🇪🇺 One aspect I particularly appreciate is that it clearly separates two distinct questions that are sometimes blended together. First, the policy question: does a multi-jurisdictional issuance model raise risks or supervisory concerns, and if so, what operational or prudential safeguards are the most appropriate? That is an important and ongoing discussion - and one that will likely continue in the context of MiCA’s upcoming consultation and formal review next year. Second, the legal interpretation question: how MiCA, as currently drafted, applies to such structures. As the note explains, the Level 1 text itself - its wording, structure and cross-references - supports the view that EMT and ART issuance can occur within global frameworks. Several MiCA Level 2 Delegated Regulations and EBA standards reinforce this interpretation, including through explicit references highlighting operating practices relevant for "those global, fungible tokens that are issued both in the EU and outside of the EU". Keeping these two discussions analytically distinct helps promote clarity in the ongoing conversation around MiCA’s implementation and possible review. Congratulations to Max Atallah for the thoughtful analysis, and to Dr. Nina-Luisa Siedler and Mariana de la Roche Wills for continuing to provide a great platform for substantive regulatory dialogue. Link to full paper in the comments 👇

Link to full paper: