The EBA drew the line in June. Zerohash is the first stablecoin infrastructure layer in Europe authorized under both MiCA and electronic money law.

Three separate regulatory facts sit in that paragraph. The two licenses come from different Dutch authorities under different legal frameworks. The EEA passporting connects them. The sequence is the point.

This is not a single announcement. Four distinct regulatory and commercial facts are compressed into the same press release, each carrying a different status and implication.

Rows one through three are regulatory facts on the ground. Row four is the commercial claim the dual license enables. The EMI row is the one that resets the sector standard.

The dual-license structure separates two legally distinct activities that a B2B stablecoin infrastructure provider performs simultaneously, and assigns each to its correct regulatory container.

• The two licenses cover different legal activities, not different products. The same USDC transfer can be a crypto-asset custody operation (MiCA CASP) or a payment transaction (EMI), depending on whether Zerohash holds it for the client or routes it on the client's instruction. Both licenses are needed to offer both services.
• The Netherlands passport is the efficient choice. AFM and DNB both sit in Amsterdam. One entity, two licenses, one passporting jurisdiction. The same structure that Circle chose for its French ACPR EMI in Paris: anchor in one regulator, passport to all 27.

The EBA's June 2025 no-action letter closed the loophole the sector was using. Before June 2025, a firm with a MiCA CASP authorization could argue that stablecoin custody and transfer for clients was a crypto-asset service, covered by MiCA, and not a payment service requiring a separate EMI or payment institution license. The EBA disagreed. It ruled that holding and transferring stablecoins on behalf of clients is a payment service under PSD2 when the stablecoins function as e-money. Firms had until March 2, 2026 to obtain a PI or EMI license or stop providing those services. The deadline has passed. Zerohash complied first.

The competitive pressure is immediate. The dual-license structure is now the minimum viable compliance posture for any B2B stablecoin infrastructure provider in the EEA. Zerohash holds both. Its competitors do not, or have not confirmed it publicly. That gap is an institutional sales advantage: a regulated bank or neobank routing stablecoin settlement flows needs a counterparty that is fully licensed for the service. "We are working on the EMI application" does not clear compliance review. "We hold it" does.

Interactive Brokers Europe as the anchor client is the credibility signal. Interactive Brokers Group raised its stake in Zerohash in September 2025, leading the firm's $104M Series D-2 at a $1B valuation. The same firm is now a live B2B client in Europe. That is not a pilot; it is a production client at institutional scale, confirming that the dual-license structure works in practice, not only in theory.

• No enforcement action has been announced. The EBA set the March 2026 deadline but has not published enforcement guidance against non-compliant infrastructure providers. A firm without an EMI license may still be operating in the EEA with no immediate consequence beyond regulatory risk.
• Circle's French ACPR EMI covers issuance, not B2B brokerage. Circle received its EMI license from the ACPR in July 2024 to issue USDC and EURC as e-money tokens under MiCA. That license covers the issuer function. It does not license Circle to provide brokerage infrastructure services to other firms' clients. The two EMI structures are not comparable.
• Individual EEA member states may require local registration. The Netherlands passport covers EEA member states under EU law, but some regulators have applied additional local requirements to payment institutions operating in their jurisdiction. The passport is broad; the practice is uneven.
• The license covers current stablecoin flows, not future product types. Tokenized deposits, tokenized money market fund shares, and hybrid instruments may require different regulatory treatment as MiCA's Level 2 technical standards evolve through 2026 and 2027. The dual-license structure is the answer for today's stablecoin; the answer for tomorrow's tokenized euro-denominated instrument may differ.
• Volume data is absent from the announcement. The press release does not disclose the scale of stablecoin flows Zerohash Europe processes. The compliance milestone is confirmed; whether the business behind it is material at the European level is not established.

The MiCA transitional period ends on July 1, 2026. After that date, firms providing crypto-asset services in the EU without full MiCA authorization can no longer rely on grandfathering arrangements. More than 40 CASPs were fully authorized under MiCA as of early 2026, per ESMA's registry. None have been publicly confirmed as also holding EMI status. The field is six weeks from the transitional cliff, and Zerohash is the only confirmed dual-license holder.

The structural context for the euro stablecoin layer matters here. The SG-FORGE EURCV and USDCV deployment on Canton Network in our May 17 briefing showed the issuer side of MiCA stablecoin infrastructure advancing. Zerohash's EMI license advances the distribution and routing side. The two are complementary: an issuer with a MiCA EMT authorization produces the instrument; an infrastructure provider with a MiCA CASP and EMI routes it to institutional clients. Both layers need to be licensed for the flow to be fully compliant end-to-end. The two-license architecture Zerohash now holds is the distribution-side answer to the question SG-FORGE answered on the issuance side.

Qivalis, the planned euro stablecoin issuer backed by French banking groups, has announced a H2 2026 launch. When it issues, its distribution infrastructure will need to route euro-denominated e-money tokens through licensed B2B providers. The EMI license is the credential that puts Zerohash on that shortlist and keeps firms without one off it.

The EBA's June 2025 no-action letter established that routing stablecoin payment flows for institutional clients is a payment service requiring an EMI or PI license, not just a crypto-asset service covered by MiCA CASP authorization. Zerohash Europe is the first infrastructure provider to satisfy both requirements from a single Netherlands entity, with full EEA passporting of each. The July 1, 2026 MiCA transitional period end removes the last cover for firms still operating without full authorization. Any competitor providing B2B stablecoin settlement to European clients without both a MiCA CASP and an EMI or PI license is now in a gap the regulator explicitly named and the compliance timeline has now closed.

Three things to watch:

• Which firm obtains the second dual license, and from which regulator. The Netherlands is not the only viable passporting jurisdiction. A French or German EMI alongside a MiCA CASP from a second NCA would confirm the architecture is replicable, not unique to Zerohash's Amsterdam setup.
• EBA enforcement posture before July 1. Whether the EBA publishes guidance or initiates proceedings against infrastructure providers still operating without an EMI or PI license will determine whether the March 2026 deadline has teeth beyond voluntary compliance.
• Zerohash's next tier-1 bank or neobank client in Europe. Interactive Brokers Europe is production-live. The next client announcement will set the commercial scale of the dual-license advantage and test whether institutional demand for fully compliant stablecoin routing infrastructure is broad or narrow.