USDC, USDT, EURC: How Should a Company Build Its Approved Stablecoin List?
A supplier requests USDC. A customer offers to settle an invoice in USDT. Treasury is considering EURC for euro-denominated flows. Each proposal requires a decision about a specific payment arrangement, rather than a blanket approval of a token name.
An approved stablecoin list should answer one operational question: can the company use this asset, on this network, for this purpose, within these limits, with a documented exit route?
For a company established in France, the assessment also needs to reflect the applicable European framework. The approval register turns that assessment into instructions treasury can execute and reviewers can verify.
1. Approve a configuration
“USDC approved” leaves too much unresolved. Is the asset native USDC issued by Circle, or a bridged representation? Which network and token identifier apply? Is approval for payments, receipts or temporary holdings?
Circle publishes USDC contract identifiers and distinguishes native issuance from bridged representations. An interface ticker is therefore insufficient evidence of identity. [6]
Each approval should specify:
Asset: token, reference currency, issuer and documented classification.
Network: production blockchain and official token identifier.
Representation: native issuance, bridged token or another structure requiring its own assessment.
Purpose: supplier payments, customer receipts, intragroup transfers or temporary holdings.
Operating route: wallet or custody arrangement, service providers and redemption or conversion channel.
Approval on one network does not automatically extend to another. Permission to make payments also does not authorize lending or using a yield protocol.
2. Keep the regulatory checks separate
Assess the token and issuer, the service provider, and the company’s intended transaction separately.
MiCA defines an e-money token, or EMT, by reference to a single official currency. Article 48 sets conditions for public offers and admission to trading in the Union, including issuer status and a notified and published white paper, subject to the relevant exemptions. [1]
A provider’s permitted services require a separate check. Custody permission should not be treated as permission to provide every service. The AMF entry for Circle Internet Financial Europe specifies custody and transfer services and describes the Article 60 notification route. [3]
USDC and EURC. Circle’s documentation identifies Circle Internet Financial Europe SAS, an electronic money institution, within its European issuance arrangements. Treasury should match that documentation to official records and the terms applicable to the company. It does not establish that every network, provider or use is suitable. [3][4]
USDT. A request involving this token should pass the same checks. “USDT is banned in Europe” is too broad to describe the issues. The reviewed guidance addresses public offers, admission to trading and certain services involving non-MiCA-compliant ARTs and EMTs. ESMA distinguishes those restrictions from mere custody and transfer, which it says should remain possible. That distinction establishes neither USDT’s eligibility for a corporate list nor the availability of a particular route. [2]
Approval needs current evidence for the proposed arrangement. If the assessment cannot establish eligibility, the configuration remains unapproved. An internal exception cannot make an unlawful transaction lawful.
3. Apply entry conditions before scoring candidates
A weighted score can conceal a decisive weakness. Market liquidity cannot compensate for uncertain token identity or an unusable exit route.
The proposed BECTRA method begins with four entry conditions:
Documented eligibility: evidence supports the applicable framework for the token, issuer, providers and intended use.
Verified identity: network and token identifiers match the official sources retained in the file.
Usable exit: the company can access a documented redemption or conversion route.
Executable controls: it can authorize, execute, record and reconcile the operations.
Candidates that meet these conditions can then be compared on reserve transparency, liquidity for the company’s transaction sizes, network availability, costs and concentration of dependencies. Evidence needs a date; an old reserve report should not be treated as a current description.
These are proposed governance controls, rather than a general MiCA checklist imposed on every corporate holder.
4. Establish the exit route first
Article 49 gives EMT holders a claim against the issuer and provides for redemption at par on request. Exercising that right also requires an operational process. [1]
The approval file should identify:
Counterparty: the entity handling redemption or conversion.
Access: account setup, identity checks and required documents.
Timing: when funds can reach an available bank account.
Cost: network, provider and foreign-exchange costs along the route.
Fallback: an assessed alternative if the main route becomes unavailable.
Circle’s redemption policy distinguishes customers from other holders, describes access and verification requirements for professional holders, and addresses stress events. Treasury should prepare this process before it relies on redemption for liquidity. [5]
A small test establishes what worked under the test conditions. It does not demonstrate capacity for a much larger transaction or uninterrupted access during an incident.
5. Set limits around exposures and dependencies
Each approval needs amount and holding-period limits. These can apply to total exposure, issuer, reference currency, service provider, network and individual transactions.
A euro-based company holding a dollar-referenced token also has EUR/USD exposure, even when the token maintains its dollar peg.
Multiple tickers do not necessarily diversify issuer risk. USDC and EURC can serve different currency needs while retaining dependencies on the Circle group. Multiple networks can also depend on one custody or conversion provider. [4]
Track limits by dependency using a consistent valuation rule. The amounts and permitted holding periods are internal decisions based on liquidity needs and accepted risks.
6. A payment within the amount limit can still be outside approval
Consider a fictional company approving native USDC on Ethereum for selected dollar-denominated supplier payments. Its policy includes:
maximum exposure of USD 100,000 equivalent, measured under its internal valuation rule;
25,000 USDC per payment;
a maximum holding period of five business days;
an identified wallet, a tested conversion route and dual approval;
exclusion of bridges and yield transactions.
These figures are illustrative, not regulatory thresholds or universal recommendations.
The supplier then requests 20,000 USDC on another network. The amount is within the limit, but the arrangement is outside the approved scope. Treasury needs approval for the new network and route before executing, or must agree a payment method already permitted.
An unsolicited receipt of an unapproved token likewise does not add it to the list. Record the incident, identify the asset and flow, and decide the appropriate treatment before making another transfer.
7. Give approvals a lifecycle
Use four clear statuses:
Approved: permitted within the documented scope and limits.
Conditionally approved: restricted to defined routes, amounts or periods, with conditions met before use.
Suspended: new operations blocked; existing holdings handled under a specific decision and procedure.
Not approved: use excluded, with the reason retained.
Alongside scheduled reviews, define event triggers: regulatory changes, contract changes, reduced reserve transparency, redemption difficulties, price deviations, network incidents or provider changes.
The procedure should name the person monitoring each trigger, the person able to suspend new flows and the authority deciding how to handle existing holdings. Suspension should not mean an automatic sale regardless of execution conditions.
Retain the decision owner, approval date, evidence and next review date. Translate the approved register into the tools and procedures used by treasury.
Conclusion — Make approval verifiable
The method follows PURPOSE → ELIGIBILITY → TOKEN/NETWORK → EXIT → LIMITS → APPROVAL → REVIEW.
The practical output is an approval record for each configuration, supported by dated evidence, an owner and a status. It enables treasury to assess a real payment request without rebuilding the entire analysis each time.
How BECTRA can help
BECTRA supports the design and review of eligibility criteria, approval records, exposure limits, dependency maps and change or suspension procedures. The work connects the financial decision to its execution and control evidence.
Further reading
Sources
Consulted on 5 October 2026. Proposed thresholds, entry criteria, statuses and procedures are part of the BECTRA method; the following sources support the legal and technical facts.
MiCA: Article 3, Article 48, Article 49.
European Commission / ESMA: Q&A 2404, statement of 17 January 2025, MiCA register. The register page retrieved reports an update on 30 September 2026; this article does not claim an exhaustive extraction of the issuer file.
Circle: MiCA USDC white paper, Circle France FAQ.
Circle: MiCA Redemption Policy, 15 September 2026 version.
Circle: USDC contract addresses, Bridged USDC Standard.
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