One of the most interesting elements in the European Commission’s new consultation on the functioning of MiCA is the section on global stablecoins and multi-issuance models 🇪🇺 While this was always clear to those who followed MiCA closely - from the original impact assessment through the Level 1 adoption and subsequent Level 2 standards - it is notable to see the Commission publicly acknowledge that MiCA, as currently drafted, is open to multi-issuer structures (see question 30 attached). Too often, previous discussions blended together two separate questions: • The legal interpretation question: whether MiCA legally permits multi-issuance • The policy and risk question: whether such models raise supervisory, prudential, or operational concerns, and what safeguards should apply Those are distinct issues. On the legal interpretation, previous legal analyses - including for example the thoughtful DARTE note by Max Atallah (link in comments) - have consistently concluded that MiCA’s text, structure and level two measures clearly and explicitly support global and multi-jurisdictional issuance arrangements. The Commission’s consultation language now provides further public confirmation of that reading. This is important because it allows the debate to move toward the real policy questions during the consultation process: ➡️ What safeguards are the most effective today? ➡️ Which additional safeguards, if any, should be implemented to mitigate risks? ➡️ How are other regulatory frameworks (e.g. U.S., UK, Singapore) approaching foreign stablecoins and what can the EU learn from that (e.g. equivalence assessment, tiered approach)? Thoughtful discussion around these questions during the consultation will help ensure MiCA's stablecoin framework remains robust, effective, and globally aligned --> Link to the consultation in the comments.(Patrick Hansen)