If We Already Hold a Traditional Payment License, Do We Need a New License to Add Stablecoin Collection and Payment Services?

Short answer

It is not necessarily required to apply from scratch, but the scope of the license must be re-examined. A traditional payment qualification does not automatically cover stablecoin custody, exchange and transfer; some institutions may follow a statutory notification or license-variation path, while others require separate authorization. The key factors are the license category held by the existing entity, the proposed new functions, and the local legal classification of stablecoins.

Cross-border finance and crypto paymentsWhether the business can be carried out

First, verify what the original license permits

"Payment company" is merely an industry label; the actual qualification may be money remittance, acquiring, e-money issuance or other services. The review should begin with the licensing decision, the attached conditions and the public register, and then compare each item against the new product. A distinction should also be drawn between using stablecoins to settle fiat currency on one's own account and directly providing customers with services to buy, hold and transfer coins: the obligations owed to customers differ between the two products, and the original market-access conclusion cannot simply be carried over merely because both are embedded in the existing payment page. At the same time, check whether the original license is subject to restrictions on business scale, customer type or geographic scope of service. Adding a stablecoin function may change the business and risks described in the original application even if the licensed entity remains unchanged.

The EU notification route is not available to all payment institutions

Article 60 of MiCA establishes a route for certain financial institutions to provide some crypto-asset services. Among these, the notification arrangement for e-money institutions concerns the custody and transfer of e-money tokens they issue themselves; it does not permit them to operate all third-party stablecoins under their original license. Ordinary payment institutions also cannot assume that they fall within the institutions listed in that article merely because they belong to the financial sector. Whether the applicable route is notification, application for CASP authorization or expansion of an existing authorization should be matched item by item against the entity and the service.

Assume a new "stablecoin payment" button is added

An offshore company that already has a fiat-currency collection business plans to let customers deposit stablecoins into a platform balance and then pay suppliers. The new function does not merely add a payment option; it introduces asset custody, transfer authorization and on-chain exception handling. If a qualified third party instead contracts directly with customers and undertakes these services, the company's role may differ; however, the actual interactions and contracts should be examined, rather than merely adding the partner institution's name at the bottom of the page.

Check qualification changes together with operational changes before launch

EU EMT services also involve an intersection between MiCA and PSD2, and the EBA continues to address the interface between authorizations in its 2026 opinion; earlier regulatory transition recommendations cannot be understood as a permanent exemption. In practice, the company should also re-obtain confirmation from banks and payment channels regarding the new business, and update customer terms, asset segregation, refunds, wallet permissions and incident response plans. Bank confirmation here is a check of cooperation feasibility and does not mean that a bank can approve a business that is otherwise not permitted by law.

Recommended actions

Prepare a gap table comparing the original license scope with the new functions, and clearly define the boundary between operating in-house and operating through third parties.
If relying on a notification or an add-on, record the specific provisions, preconditions and procedures of the competent authority.
Set the threshold for launching real transactions only after completing changes to bank, upstream channel and customer contracts.

Information note: This article provides general information only and does not replace legal advice based on specific facts.