Stablecoin issuance legal advisor: EU EMT, UAE and US routes

A stablecoin issuance legal advisor decides which regulator your token answers to, builds the entity that regulator will authorise, and runs the application with its reserve, redemption and disclosure record. Infinilex does that on three routes: an EU e-money token under MiCA, where EU local counsel we manage make the filing; a dirham or foreign-currency payment token under the CBUAE regulation; and a US permitted payment stablecoin issuer under the GENIUS Act, whose final rules were still proposals as at 25 September 2026.

The five-market comparison is on where to issue a stablecoin; this page is the engagement: what we do, in what order, and who signs. It serves anyone looking for a stablecoin licence consultant in Dubai, where the dirham fork decides whether the CBUAE or VARA is your regulator, or a stablecoin issuance consultant for an Indian founder, where the issuer sits abroad and the India leg is FEMA and FIU-IND work.

Schedule A: the three issuance routes side by side

Schedule A · Three issuance routes from the regulator texts, as at 25 September 2026
Dimension	EU: e-money token under MiCA (home competent authority)	UAE: payment token under the CBUAE Payment Token Services Regulation (Circular 2/2024)	US: payment stablecoin under the GENIUS Act (Public Law 119-27)
Entity the regulator authorises	An EU-authorised credit institution or electronic money institution; white paper notified before issuance (Art 48).	Dirham (licensed): a UAE company outside the financial free zones, issuing as its exclusive business, AED 15 million capital plus 0.5 percent of outstanding face value (Arts 6, 13, 17). Foreign (registered): a person incorporated outside the UAE or in a financial free zone, with SCA or local licensing authority non-objection and a legal opinion on every token (Art 9).	An insured depository institution subsidiary, a Federal qualified issuer or a State qualified issuer (Secs 2, 3(a)); a non-financial public company also needs a unanimous Stablecoin Certification Review Committee vote (Sec 4(a)(12)).
Reserve rules	At least 30 percent of invested funds in separate credit-institution accounts, the rest in low-risk, same-currency liquid instruments (Art 54).	Dirham: cash in a separate escrow account at a UAE-licensed bank outside the group, reconciled daily, audited monthly (Art 22). Foreign: a same-currency reserve equal to tokens issued, externally audited and published (Art 9(8)).	At least 1:1 in US currency, Federal Reserve deposits, insured demand deposits, Treasury bills of 93 days or less, overnight Treasury repo and government money market funds; a monthly composition report examined by a registered public accounting firm and certified by the CEO and CFO (Sec 4(a)(1)).
Redemption	At par, in funds, at any time, no fee (Art 49).	At par in fiat by the next business day; no time limit on requests; fees only where proportionate to costs (Art 21).	A published redemption policy with clear and conspicuous procedures for timely redemption, all fees disclosed (Sec 4(a)(1)(B)).
Interest to holders	Banned, including any benefit tied to holding period; extends to crypto-asset service providers (Art 50).	Banned, directly or through another person (Art 12(3)); applied to foreign issuers through Art 9(7).	Banned: no interest or yield solely for holding, using or retaining the token (Sec 4(a)(11)).
Timeline band	Live since 30 June 2024 (Art 149); one authorisation passports across the single market.	Live per the Rulebook since 31 August 2024; the Article 40 transition year has ended. No decision deadline is stated; an application suspended six months or more starts again (Art 7).	Enacted 18 July 2025 but not live: no final rule as at 25 September 2026, so the effective date tracks 18 January 2027 (Sec 20). A decision is due within 120 days of a substantially complete application (Sec 5); the Act is not yet effective.

Sources, read 25 September 2026: Regulation (EU) 2023/1114 (MiCA); CBUAE Payment Token Services Regulation; GENIUS Act; OCC Bulletin 2026-3 (proposed rule). Non-dirham tokens in Dubai outside the DIFC fall under VARA’s Virtual Asset Issuance Rulebook; ADGM and DIFC issuers answer to the FSRA and DFSA (ADGM and DIFC crypto licensing).

What stablecoin issuance advisory covers

The route memo. Reference currency and first distribution market, mapped to the regulator they point at and its rules, and the routes rejected.
Group structure around the issuer. Each route wants a specific issuer: an EU EMI or credit institution, a UAE company whose exclusive business is issuing, or a US permitted issuer type. The technology company and treasury sit where their own rules are met: cross-border structuring.
The EU EMT programme. Perimeter and member-state analysis, the EU issuer and its management, the Article 49 and 54 reserve and redemption design, the white paper and the evidence pack. Infinilex quarterbacks it; EU local counsel files it. A CASP authorisation for an exchange arm is on MiCA authorisation.
The CBUAE licence or registration. Dirham token: the UAE company, the Article 22 escrow reserve, the Article 6(5) independent assessment report and the Article 26 white paper; a licensed dirham token is issued only to UAE residents (Art 2(6)). Foreign-currency token: the registration, the non-objection and the Article 9(4) legal opinion; UAE merchants may accept it only as payment for virtual assets or their derivatives (Art 2(7)).
US GENIUS readiness. The permitted issuer type, the Section 4 reserve, redemption, reporting and certification policies and the interest ban, built against the statute and adjusted as the final rules arrive. The statute contemplates foreign payment stablecoin issuers (Sec 3(b)(2)) and the OCC’s proposed rule of 25 February 2026 covers them; that leg is scoped once the rule is final.
Reserve, redemption and yield design. All three routes ban interest to holders; MiCA and the CBUAE regulation also catch benefits tied to holding time. Features that pay users are tested against each ban: stablecoin yield across jurisdictions. Infinilex is a Circle Alliance Program member.
The India leg. India has no issuance regime (why is on where to issue a stablecoin), so the issuer sits abroad and the India work is the FIU-IND perimeter, holdings under FEMA and the related-party file: FIU-IND registration and FEMA, ODI and LRS compliance.

How a stablecoin issuance engagement is staged

Fixed-scope stages, mapped on a free discovery call.

Route memo. Reference currency, distribution map, regulator, issuer type and the rules that follow.
Group structure and India leg. The issuer, technology and treasury entities, the intercompany agreements, and the FEMA and FIU-IND analysis for any Indian shareholder or operating company.
Application programme. EU: the EMI or credit institution route, filed by EU local counsel. UAE: the Article 7 pre-application meeting, the application with its independent assessment report and white paper and, for foreign tokens, the Article 9(4) legal opinion. US: the permitted issuer file, held for the final rules.
Reserve, redemption and disclosure operating model. The escrow or credit-institution accounts, the reconciliation and audit calendar, the redemption procedure and published policies.
After authorisation. A monthly retainer for reporting, white paper updates, regulator queries and the AML programme, or hand-over.

Scope notes and the project or retainer choice: how engagements work.

Who signs what on stablecoin issuance work

Infinilex counsel qualified for the relevant UAE regulator sign the UAE leg, including the Article 9(4) or 6(7) legal opinion. Infinilex counsel admitted in the US sign the US leg. Infinilex counsel enrolled as advocates in India sign the India leg, with Infinilex’s company secretary or chartered accountant where a statute names that professional. On the EU leg, Infinilex scopes the work, builds the record and briefs the EU local counsel who file and sign; they are brought in explicitly and named to you before they act. Statutory signatories stay as the texts name them: the issuer submits its own white paper and application, an external auditor audits the reserve, the CEO and CFO certify the GENIUS monthly report, the company or its directors sign Form FC and the Annual Performance Report, and the AD bank reports to the RBI.

Frequently asked questions

What does Infinilex do on an EU EMT authorisation, and what do EU local counsel do?

Under MiCA Article 48 an e-money token may be issued only by an EU-authorised credit institution or electronic money institution. Infinilex runs the perimeter analysis, the member-state choice, the group structure, the reserve and redemption design and the evidence pack. EU local counsel we select and brief make the regulator-facing filings and sign the EU documents, and are named to you before they act. Infinilex quarterbacks it; EU local counsel files it.

Which stablecoin route needs a UAE entity, and which does not?

A dirham payment token does. Under the CBUAE Payment Token Services Regulation a Dirham Payment Token Issuer must be a UAE-incorporated company outside the ADGM and DIFC financial free zones, with issuing as its exclusive business and, as at 25 September 2026, AED 15 million of capital (Article 13). A foreign-currency payment token does not: a person incorporated outside the UAE, or in a financial free zone, registers as a Foreign Payment Token Issuer instead, which still needs SCA or local licensing authority non-objection and a legal opinion on every token.

Can Infinilex prepare a US GENIUS Act issuer application before the final rules are out?

The readiness work, yes; the filing waits for the regulator. As at 25 September 2026 the GENIUS Act is Public Law 119-27 with no final implementing rule, so the effective date tracks 18 January 2027. The statute already fixes the issuer types, the 1:1 reserve, the redemption policy, the monthly certified reserve report and the interest ban, so the analysis, policies and structure are built against the Act and adjusted when the final rules land.

Does the CBUAE require a legal opinion on a payment token?

For a foreign payment token, yes: Article 9(4) of the Payment Token Services Regulation requires a Foreign Payment Token Issuer applicant to obtain a legal opinion on all its foreign payment tokens, covering compliance and the white paper. For a licensed dirham issuer, Article 6(7) lets the Central Bank require one on whether the tokens and operations comply, including the reserve. Infinilex counsel qualified for the relevant UAE regulator sign that opinion.

What does the India leg of a stablecoin issuance engagement cover?

India has no stablecoin issuance regime, so the issuer sits abroad and the India leg is structuring, not licensing: whether any Indian activity brings an Indian entity inside the FIU-IND reporting perimeter; how the founders and any Indian company hold the foreign issuer under FEMA through ODI or LRS; and the related-party file with the Indian technology company, with the 30 percent VDA tax and 1 percent TDS modelled. Infinilex counsel enrolled as advocates in India sign this leg.

Next step

Tell us the currency and where the first users sit.

Send one paragraph on the token, its reference currency and its first markets; on the discovery call we will say which regulator it points at and which issuer entity it wants.

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Stablecoin issuance, scoped and run across the EU, UAE and US.