On 2 June 2026, the European Banking Authority and the New York State Department of Financial Services signed a Memorandum of Understanding on supervisory cooperation and information exchange for entities conducting cross-border stablecoin activities. The instrument is in force and operates alongside the Markets in Crypto-Assets Regulation, which entered full application in December 2024.
Article 126 of Regulation (EU) 2023/1114 (MiCA) authorises the EBA to conclude administrative arrangements on information exchange with supervisory authorities of third countries where equivalent confidentiality standards are met. The EBA assessed the NYDFS supervisory confidentiality regime and confirmed it meets that equivalence threshold. The MoU establishes procedures for information exchange and coordination of supervisory activities covering entities issuing stablecoins in both New York State and the EU, including entities subject to direct EBA supervision as issuers of significant asset-referenced tokens or significant e-money tokens under MiCA Titles III and IV.
Stablecoin issuers operating in both New York and the EU now face concurrent oversight from DFS and the EBA under a coordinated supervisory arrangement. Both authorities are obliged to share supervisory information and coordinate ongoing supervision, reducing the risk of conflicting regulatory demands on dual-jurisdiction issuers. The MoU also sets out procedures for mutual assistance in crisis situations, meaning that a stress event affecting a cross-border stablecoin issuer may prompt faster cross-jurisdictional coordination. Issuers holding both a DFS authorization and a MiCA licence should treat material supervisory findings, enforcement actions, and licensing decisions taken by either authority as potentially visible to the other under this arrangement.
The MoU does not alter the domestic licensing requirements of either jurisdiction. Issuers must separately satisfy DFS stablecoin guidance and the NYDFS proposed payment stablecoin regulation announced on 9 June 2026, and must meet MiCA Title III or Title IV requirements in the EU. A prior EBA-NYDFS MoU from October 2021 governs general banking supervisory cooperation; the June 2026 MoU is specific to stablecoin activities under Article 126 of MiCA.
Licentium advises stablecoin issuers and digital asset businesses operating across EU and US jurisdictions on regulatory compliance and cross-border licensing strategy. We monitor EBA and NYDFS developments and can assess the supervisory implications of the new MoU for your operations. Contact us to discuss how concurrent EU-US stablecoin oversight affects your business. Work we undertake includes MiCA authorization strategy, DFS BitLicense compliance, cross-border supervisory response planning, stablecoin reserve structuring, and EU-US regulatory gap analyses.