airKUNAairkuna.org is an educational project. When we explain how a euro stablecoin is issued and why it matters for the local economy, we owe you an equally frank explanation of the other side: where the regulated territory begins. This guide is written for founders, developers and the merely curious — as a map, not as legal advice.
First: a euro stablecoin is not "just a token"
Everything else hangs on a single chain of legal qualification. A regulated euro stablecoin — the publicly known example being EURe, issued by Monerium EMI hf., an electronic money institution licensed by the Central Bank of Iceland and passported across the EEA — is an e-money token (EMT) under MiCA. An EMT is legally treated as electronic money. And electronic money constitutes "funds" under the Payment Services Directive.
The consequence is awkward and widely overlooked: the same service, over the same token, can simultaneously be a crypto-asset service under MiCA (supervised by HANFA) and a payment service under PSD2 (supervised by the Croatian National Bank). This is known as dual authorisation.
e.g. EURe"]:::tok --> B["E-money token
EMT · MiCA Title IV"]:::mica B --> C["Legally = electronic money
E-Money Directive"]:::mica C --> D["= funds
Payment Services Directive"]:::psd D --> E{"A service over it can be both
a crypto service and a payment service"}:::key E -- "MiCA" --> F["CASP authorisation
HANFA"]:::hanfa E -- "PSD2" --> G["Payment institution
Croatian National Bank"]:::hnb classDef tok fill:#fff,stroke:#002F6C,color:#002F6C,font-weight:600; classDef mica fill:#002F6C,stroke:#001631,color:#fff,font-weight:600; classDef psd fill:#0A3B82,stroke:#001631,color:#fff,font-weight:600; classDef key fill:#fff,stroke:#C8912A,color:#002F6C,font-weight:600; classDef hanfa fill:#C8912A,stroke:#9a6f1f,color:#fff,font-weight:600; classDef hnb fill:#1A7A3C,stroke:#0c3f23,color:#fff,font-weight:600;
Who supervises what: HANFA and the Croatian National Bank
Croatia allocated supervisory competence through the Act implementing Regulation (EU) 2023/1114 (Official Gazette 85/2024). In short: crypto services go to HANFA, money and payments go to the central bank — and a stablecoin, as we saw, tends to be both.
| Authority | Competence under MiCA | Other relevant competences |
|---|---|---|
| HANFA Croatian Financial Services Supervisory Agency |
Titles II, V and VI — issues authorisations to crypto-asset service providers (CASPs), supervises offerors of other crypto-assets; contact point towards ESMA | Crowdfunding (ECSP), capital markets, investment and pension funds, insurance, leasing, factoring |
| Croatian National Bank | Titles III and IV — authorises issuers of asset-referenced tokens, supervises EMT issuers (credit institutions and e-money institutions); contact point towards the EBA | Credit institutions, payment institutions, electronic money institutions, payment systems, bureaux de change |
The ladder: six levels of a project
Rather than starting from a list of licences, it is more useful to ask how deeply the project reaches into other people's money. Each level adds obligations to the one before it. The boundary between level 0 and everything else is the only one that genuinely changes a project's life.
land in your account?"}:::q Q1 -- "yes" --> R3A["Level 3 · CASP custody and transfer
+ payment institution"]:::hard Q1 -- "no" --> Q2{"Do you hold
users' keys?"}:::q Q2 -- "yes" --> R3B["Level 3 · CASP custody
+ payment layer"]:::hard Q2 -- "no" --> Q3{"Does your backend
initiate payments?"}:::q Q3 -- "yes" --> R3C["Level 3 · payment initiation service
= payment institution"]:::hard Q3 -- "no" --> Q4{"Exchange from
your own position?"}:::q Q4 -- "yes" --> R2["Level 2 · CASP exchange,
execution and reception of orders"]:::mid Q4 -- "no" --> Q5{"Raising funds
from the public?"}:::q Q5 -- "yes" --> R4["Level 4 · ECSP or prospectus
or alternative investment fund"]:::hard Q5 -- "no" --> Q6{"Issuing your own
stablecoin?"}:::q Q6 -- "yes" --> R5["Level 5 · e-money institution
+ MiCA Title IV"]:::worst Q6 -- "no" --> R0["Level 0 · no licence"]:::good classDef q fill:#fff,stroke:#C8912A,color:#002F6C,font-weight:600; classDef good fill:#1A7A3C,stroke:#0c3f23,color:#fff,font-weight:600; classDef mid fill:#C8912A,stroke:#9a6f1f,color:#fff,font-weight:600; classDef hard fill:#002F6C,stroke:#001631,color:#fff,font-weight:600; classDef worst fill:#C0181C,stroke:#7a1418,color:#fff,font-weight:600;
Pure software — you touch nothing that belongs to others
Operating under someone else's licence
You touch others' tokens, but not their money
You hold, transfer or initiate someone else's funds
You raise funds from the public
You issue your own euro stablecoin
Seven scenarios, seven flows of funds
The ladder is abstract; the flow of funds is not. For each typical scenario below there is a diagram with the point at which the licensing obligation arises marked explicitly. The scenarios are generic — they describe a shape of architecture, not a specific product.
Pure software
no licenceThe user is onboarded and KYC'd directly by the licensed issuer. The SEPA transfer lands in the user's own IBAN, the stablecoin is minted to a wallet whose keys only the user holds, and every transfer is signed by the user. Your application receives notifications, prepares transactions and shows balances — but never disposes of funds.
at a licensed issuer"]:::ext IB -- "mint 1:1" --> W["User's wallet
keys held by the user"]:::gold W -- "user signs" --> R(["Payee"]):::loc APP["Your application
UX, display, notifications"]:::soft -. "reads and prepares only" .-> W APP --- OK["No licence:
technical service provider"]:::good classDef loc fill:#fff,stroke:#002F6C,color:#002F6C,font-weight:600; classDef ext fill:#002F6C,stroke:#001631,color:#fff,font-weight:600; classDef gold fill:#C8912A,stroke:#9a6f1f,color:#fff,font-weight:600; classDef soft fill:#EAF0FA,stroke:#9aa9c2,color:#14202E,font-weight:600; classDef good fill:#1A7A3C,stroke:#0c3f23,color:#fff,font-weight:600;
The hold-and-forward model
CASP + payment licenceThe most common mistake in early products. Third-party SEPA transfers land in the provider's IBAN, the stablecoin is minted to the provider's wallet, and it is then forwarded to the ultimate payee. The argument that "it is only passing through, the money isn't held" is not a legal defence: the obligation arises the moment third-party funds come into your possession.
third-party value under your control"]:::bad W -- "forwarded on instruction" --> R(["Payee"]):::loc W --- L["Obligation arises here:
CASP custody + transfer (HANFA)
+ money remittance (CNB)"]:::warn classDef loc fill:#fff,stroke:#002F6C,color:#002F6C,font-weight:600; classDef bad fill:#C0181C,stroke:#7a1418,color:#fff,font-weight:600; classDef warn fill:#F4E7C6,stroke:#C8912A,color:#3a2900,font-weight:600;
Exchange from your own position
CASPThe application offers the user a swap of one token for another, or for fiat — out of your own inventory, even at zero fee. That is a crypto exchange service and requires a CASP authorisation regardless of volume.
own token inventory"]:::mid T -- "returns token B or euro" --> U T --- L["Obligation: CASP exchange of crypto-assets
for funds (c) or for other crypto-assets (d)"]:::warn N["Zero fee
changes nothing"]:::note -.-> L classDef loc fill:#fff,stroke:#002F6C,color:#002F6C,font-weight:600; classDef mid fill:#C8912A,stroke:#9a6f1f,color:#fff,font-weight:600; classDef warn fill:#F4E7C6,stroke:#C8912A,color:#3a2900,font-weight:600; classDef note fill:#EAF0FA,stroke:#9aa9c2,color:#14202E,font-weight:600;
Custody of keys
the most expensive combinationAn embedded wallet in the application where the provider holds a key, holds a multisig share sufficient to move funds alone, or controls the recovery process. The boundary is not the label but substance over form: the moment an administrative or recovery key exists, the custody analysis opens.
controlled by the provider"]:::bad K --> W["User's wallet
de facto third-party control"]:::bad K --- L["Obligation: CASP custody (a)
+ custody of EMT = operating a payment
account → payment layer"]:::warn SC["Self-custody design
avoids the whole branch"]:::good -.-> W classDef loc fill:#fff,stroke:#002F6C,color:#002F6C,font-weight:600; classDef mid fill:#002F6C,stroke:#001631,color:#fff,font-weight:600; classDef bad fill:#C0181C,stroke:#7a1418,color:#fff,font-weight:600; classDef warn fill:#F4E7C6,stroke:#C8912A,color:#3a2900,font-weight:600; classDef good fill:#1A7A3C,stroke:#0c3f23,color:#fff,font-weight:600;
The payment initiation trap
a payment licence without holding fundsThe subtlest scenario. The architecture looks clean — the user has their own account and their own wallet, the provider holds neither euros nor keys. But the backend stores the user's API token and fires instructions by itself, on a rule or a webhook. Initiating a payment from someone else's account is a distinct payment service: the licence is required even when funds never enter your possession.
stores token, rules, schedule"]:::bad -- "fires the instruction itself" --> ACC BE --- L["Obligation: payment initiation service
→ payment institution (CNB)"]:::warn FIX["Correct: the user signs
each transaction in their own session"]:::good -.-> ACC classDef loc fill:#fff,stroke:#002F6C,color:#002F6C,font-weight:600; classDef ext fill:#002F6C,stroke:#001631,color:#fff,font-weight:600; classDef bad fill:#C0181C,stroke:#7a1418,color:#fff,font-weight:600; classDef warn fill:#F4E7C6,stroke:#C8912A,color:#3a2900,font-weight:600; classDef good fill:#1A7A3C,stroke:#0c3f23,color:#fff,font-weight:600;
Raising funds from the public
ECSP / prospectus / fundThe moment third parties invest expecting a return, you leave crypto regulation and enter capital markets regulation. Three routes lead to different licences and are not interchangeable — which one applies depends on whether you run a platform, issue your own instruments, or pool funds.
expecting a return"]):::loc --> Q{"What form does it take?"}:::q Q -- "platform matching investors
and project owners" --> E["ECSP authorisation
HANFA · 3-month decision"]:::mid Q -- "your own issuance
of securities" --> P["Prospectus / capital markets act
HANFA"]:::mid Q -- "pooling funds and
investing at discretion" --> A["Alternative investment fund
manager · HANFA"]:::mid Q -- "offer of crypto-assets
to the public" --> M["MiCA: white paper
and offering rules"]:::hard classDef loc fill:#fff,stroke:#002F6C,color:#002F6C,font-weight:600; classDef q fill:#fff,stroke:#C8912A,color:#002F6C,font-weight:600; classDef mid fill:#C8912A,stroke:#9a6f1f,color:#fff,font-weight:600; classDef hard fill:#002F6C,stroke:#001631,color:#fff,font-weight:600;
Your own stablecoin
EMI + MiCA Title IVThe top of the ladder, and the only scenario where the question is not whether a licence is needed but how long it takes to obtain. An issuer of e-money tokens must be a credit institution or an electronic money institution. On top of the licence come the white paper, 1:1 backing, segregated reserves and the holder's right to redeem at par at any time.
licence · CNB"]:::hard --> L2["MiCA Title IV
white paper"]:::hard L2 --> L3["1:1 reserve
segregated, low-risk"]:::mid L3 --> L4["Smart contract
mint and burn"]:::navy L4 --> L5["SEPA on- and off-ramp"]:::navy L5 --> L6(["Right to redeem
at par"]):::gold classDef hard fill:#C0181C,stroke:#7a1418,color:#fff,font-weight:600; classDef mid fill:#002F6C,stroke:#001631,color:#fff,font-weight:600; classDef navy fill:#0A3B82,stroke:#001631,color:#fff,font-weight:600; classDef gold fill:#C8912A,stroke:#9a6f1f,color:#fff,font-weight:600;
Ten crypto services: authorisation is granted service by service
A CASP authorisation is not all-or-nothing. MiCA lists ten services and you apply only for those you actually provide. The list doubles as the fastest check of whether the regulation catches you at all.
| # | Crypto-asset service | When it fires |
|---|---|---|
| a | Custody and administration of crypto-assets on behalf of clients | As soon as you control private keys or access to user wallets |
| b | Operation of a trading platform | An order book, matching of offers |
| c | Exchange of crypto-assets for funds | Selling or buying back tokens for euro out of your own position |
| d | Exchange of crypto-assets for other crypto-assets | A swap out of your own inventory |
| e | Execution of orders on behalf of clients | You buy or sell in the user's name |
| f | Placing of crypto-assets | Distributing an issuance for the issuer |
| g | Reception and transmission of orders | You forward user orders to third parties, e.g. an exchange |
| h | Advice on crypto-assets | Personalised recommendations — mind the copy in your app |
| i | Portfolio management of crypto-assets | Discretionary management of third-party positions |
| j | Transfer services for crypto-assets on behalf of clients | You send tokens from an address you control, on the user's instruction |
The catalogue: every HANFA and central bank licence
For the complete picture, here is the full list of authorisations issued by the two regulators, flagged for how relevant each is to a typical crypto or payment project. Most are not — but it is useful to see where a project does not land.
HANFA — 16 categories of authorisation
| # | Licence or authorisation | Legal basis | Relevant to a crypto/payment project? |
|---|---|---|---|
| 1 | Insurance and reinsurance undertaking | Insurance Act | — |
| 2 | Pension insurance company | Pension Insurance Companies Act | — |
| 3 | UCITS management company | Open-Ended Investment Funds Act | — |
| 4 | Alternative investment fund manager | Alternative Investment Funds Act | latent Pooling third-party funds for discretionary investment is fund territory, whatever the technology |
| 5 | Mandatory pension fund company | Mandatory Pension Funds Act | — |
| 6 | Voluntary pension fund company | Voluntary Pension Funds Act | — |
| 7 | Investment firm | Capital Markets Act | conditional Tokenised financial instruments and investment advice fall under the capital markets act, not MiCA |
| 8 | Market intermediary | Capital Markets Act | — |
| 9 | Stock exchange | Capital Markets Act | — |
| 10 | Central securities depository | Capital Markets Act + Reg. 909/2014 | — |
| 11 | Central counterparty | Capital Markets Act + EMIR | — |
| 12 | Clearing system operator | Capital Markets Act | — |
| 13 | Leasing company | Leasing Act | — |
| 14 | Factoring company | Factoring Act | — |
| 15 | Crowdfunding service provider (ECSP) | Regulation (EU) 2020/1503, OG 144/21 | conditional Only for a platform matching investors and project owners; covers loans and transferable securities |
| 16 | Crypto-asset service provider (CASP) | Regulation (EU) 2023/1114, OG 85/24, Ordinance OG 95/25 | the central licence For every scenario in which you touch someone else's tokens |
HANFA additionally maintains registers of insurance distributors. It decides on an ECSP application within three months of a complete filing.
Croatian National Bank — 13 categories of authorisation
| # | Licence or authorisation | Legal basis | Relevant to a crypto/payment project? |
|---|---|---|---|
| 1 | Bank | Credit Institutions Act | — |
| 2 | Savings bank | Credit Institutions Act | — |
| 3 | Housing savings bank | Credit Institutions Act | — |
| 4 | Credit union | Credit Unions Act | — |
| 5 | Payment institution | Payment System Act (PSD2) | key For holding or transferring third-party funds, including e-money tokens, and for initiating payments |
| 6 | Small payment institution | Payment System Act | entry variant Cheaper, but Croatia only (no passporting) and subject to a volume cap |
| 7 | Account information service provider | Payment System Act | conditional Only for aggregating data from third-party bank accounts |
| 8 | Electronic money institution | Electronic Money Act | only for own issuance Required if you issue your own e-money or stablecoin; not for using someone else's |
| 9 | Small electronic money institution | Electronic Money Act | entry variant As above, limited to Croatia |
| 10 | Payment system operator authorisation | Payment Systems Act | — |
| 11 | Authorised bureau de change | Foreign Exchange Act | — (physical currency, not crypto-assets) |
| 12 | Issuer of asset-referenced tokens | MiCA Title III, OG 85/24 | conditional Only for tokens referencing a basket of assets, not a euro stablecoin |
| 13 | Supervision of e-money token issuers | MiCA Title IV, OG 85/24 | for your own stablecoin The issuer must be a credit institution or an e-money institution |
Statuses that are not licences, but change the picture
| Status | What it means | The boundary |
|---|---|---|
| Technical service provider PSD2 art. 3(j) |
You support the provision of payment services — IT, networks, data processing, authentication — without ever coming into possession of funds | The exclusion falls away the moment funds are touched or a payment is initiated from a third-party account |
| Distributor of electronic money | You distribute or redeem e-money in the name and on behalf of the issuer, under contract; no licence or registration of your own is required | The limits are narrow: a distributor may neither provide payment services itself nor issue e-money. Handing over tokens from your own inventory slips easily into a crypto exchange or transfer service |
| Agent of an institution | You provide payment services in the name of a licensed institution and are entered in its register, or in the supervisor's | The contract with the principal defines the scope; liability towards the client stays with the principal |
| Anti-money-laundering obliged entity | Every CASP and every payment or e-money institution is an obliged entity under the anti-money-laundering legislation | A pure software provider is not — but the moment you take any licence, a full compliance programme comes with it |
Timeline: the transition periods have expired
This is the part that goes stale fastest — and the reason advice more than a year old misleads. By mid-2026 both of the reliefs available in the early years had run out.
The golden rule
There are exactly three zones where no licence is required
Everything outside them means either a licence of your own or operating under someone else's, by contract.
Pure software
The user holds their own account at a licensed institution and a wallet whose keys they control. Money and tokens never pass through you, and the user signs every transfer.
Charging for your own services
You receive stablecoins as a merchant, for your own invoices, into your own wallet. A payee is not a payment service provider — only accounting and tax remain.
Paying from your own treasury
You pay suppliers and contributors with your own funds and your own keys. Your own payments are not a service to third parties.
And one warning alongside it: being free of charge does not exempt you from licensing, and "it's only passing through" is not a legal defence. If third-party funds land in your account for even a second, the technical provider exclusion is spent.
Sources
Every claim on this page rests on primary sources — legislation and publications of the regulators and the European supervisory authorities. Law firm commentary was used only as secondary confirmation.
Legislation · Croatia
OG 85/2024 — MiCA implementing act ↗ Zakon.hr — consolidated text ↗ OG 144/21 — crowdfunding implementing act ↗ OG 150/22 — crowdfunding ordinance ↗ Credit Institutions Act ↗HANFA
Catalogue of authorisations ↗ MiCA implementing act adopted ↗ What the MiCA Regulation is (PDF) ↗ Guidelines on CASP organisational requirements (PDF) ↗ Crowdfunding ↗ First Croatian MiCA authorisation ↗Publicly available information on EURe and its issuer: monerium.com/eure. Secondary commentary (Norton Rose Fulbright, DLA Piper, Hogan Lovells, CMS, Morgan Lewis) was used solely to confirm readings of the primary sources.