Dinaro Becomes Slovenia's First MiCA EMT Issuer: What Accounting Firms and CFOs Must Assess Now
ESMA's electronic money token register expanded again on 12 August 2026, and this time it carried a notable first: Dinaro, a Slovenian electronic money institution supervised by the Bank of Slovenia, became the first Slovenia-based issuer to appear on the EU's MiCA EMT list. The update also pushed the authorised crypto-asset service provider count to 325 and added two new entrants, Partners Banka from the Czech Republic and Germany's Volksbank Beilstein-Ilsfeld-Abstatt. For accounting firms advising EU clients and for CFOs holding or issuing stablecoins, each expansion of the ESMA register reshapes the counterparty compliance landscape that firms must map and document.
What the ESMA Register Update Covers
ESMA publishes and maintains public registers under MiCA for three categories: electronic money token issuers, asset-referenced token issuers, and authorised crypto-asset service providers. The 12 August update touched all three lists, though not all in the same direction.
The EMT register hits 43 entries
Dinaro's addition brought the EMT register from 42 to 43 entries. The company's regulatory profile shows it provides payment services that include card issuing and acquiring, and it holds Mastercard principal membership. It operates under the supervision of the Bank of Slovenia, which is the relevant national competent authority for MiCA purposes in that jurisdiction. No other EMT issuers were added or removed in this cycle.
The CASP register reaches 325 firms
The authorised CASP register, which covers firms providing services such as custody, exchange, order execution, and advice on crypto-assets, added two names. Partners Banka, a Czech lender, and Volksbank Beilstein-Ilsfeld-Abstatt from Germany both entered the list. At the same time, Czech company Altlift dropped off the register. Altlift had held authorisation to execute and transmit client orders and to provide crypto-asset advice, but its authorisation notification was dated 30 June and it was removed in early July. The net effect is a total of 325 authorised CASPs.
ART register remains empty
The asset-referenced token register, which would cover tokens pegged to baskets of currencies, commodities, or other assets, remained at zero entries. The non-compliant entity list held steady at 167 names. Both figures are material reference points for compliance teams screening counterparties: an empty ART register means no issuer currently has full MiCA authorisation for that token category, and any token claiming ART status should be treated with heightened scrutiny.
Why Slovenia's Inclusion Matters Beyond the Headline
A single new entry on a 43-item list might appear routine. It is not. Each new national jurisdiction appearing on the EMT register represents a competent authority actively supervising a MiCA-authorised issuer, which in turn means that the token in question carries the legal, capital, and redemption obligations mandated by MiCA Title III.
MiCA EMT obligations that now attach to Dinaro-issued tokens
Under MiCA, an EMT issuer must maintain liquid reserve assets at a minimum 1:1 ratio against outstanding tokens at all times. Redemption at par on demand is a statutory right for holders. The issuer must segregate reserve assets, have them managed by a third-party custodian or credit institution, and publish a white paper that has been notified to and approved by the national competent authority. Ongoing reporting obligations to the Bank of Slovenia, and by extension to ESMA, apply from the date of authorisation. These are not voluntary best-practice commitments; they are enforceable legal requirements under EU law.
For an accounting firm advising a client that holds, accepts, or processes Dinaro-issued tokens, this matters immediately. A MiCA-authorised EMT is not legally equivalent to an unregulated stablecoin, even if both are denominated in euros. The regulatory wrapper changes how the token should be assessed for credit risk, how its redeemability should be disclosed in financial statements, and what due-diligence documentation a firm needs to retain.
What the banking entrants signal
The addition of Partners Banka and Volksbank Beilstein-Ilsfeld-Abstatt to the CASP register is a separate but related signal. Both are traditional credit institutions obtaining MiCA CASP authorisation rather than crypto-native firms. Under MiCA, credit institutions already licensed under the Capital Requirements Directive can notify their national competent authority to provide crypto-asset services without a separate CASP licence, as long as they comply with the relevant MiCA conduct and prudential provisions. Their appearance on the register confirms that regulators across two EU member states have processed and accepted those notifications. The trend of established banks entering the CASP register has direct implications for corporate treasury teams: it broadens the pool of regulated counterparties for custody and exchange services, which may alter risk-weighting decisions and banking relationship strategies.
Accounting and Reporting Implications for EU Firms
The practical accounting questions that arise from each ESMA register update are not trivial, and the Dinaro addition crystallises several of them.
Classification of EMT holdings on the balance sheet
Under IFRS, crypto-assets held by an entity are generally classified either as intangible assets under IAS 38 or, if held for sale in the ordinary course of business, as inventory under IAS 2. An EMT that is redeemable at par on demand from a MiCA-authorised issuer has a different risk profile from an algorithmic or unbacked stablecoin. Firms applying IAS 32 and IFRS 9 should assess whether an EMT constitutes a financial instrument, specifically a financial asset, given the contractual right to receive a fixed amount of the reference currency. That analysis is fact-specific, but the MiCA authorisation status of the issuer is a directly relevant input.
ESMA's own technical standards under MiCA also require that EMT issuers produce periodic disclosures on reserve composition. Accounting firms can use those disclosures as audit evidence when assessing the recoverability and fair value of a client's EMT holdings. Crucially, the absence of that disclosure from a token claiming EMT status, or a token whose issuer does not appear on the ESMA register, is itself a red flag requiring documentation.
Digital asset accounting software and register mapping
MiCA compliance crypto workflows increasingly depend on technology that can map tokens to their regulatory status in real time. As the ESMA register updates occur on a rolling basis, firms relying on static spreadsheets to classify stablecoin counterparties will fall behind. Robust crypto accounting software should be able to ingest ESMA register data and flag holdings in tokens issued by entities on the non-compliant list, or tokens whose issuer does not appear on either the EMT or ART register. The Altlift removal is a case in point: a firm that had assessed Altlift as a regulated CASP counterparty in June needs to update that assessment following the July removal. Systems that do not automate this check will require manual review cycles that are slow and error-prone as the register continues to grow.
AML and KYC obligations linked to CASP status
The Travel Rule applies to crypto-asset transfers involving CASPs operating in the EU under MiCA. As the CASP register grows, firms transferring crypto-assets to or from a registered CASP must comply with travel rule data requirements, including the transmission of originator and beneficiary information. Conversely, transfers involving entities on the non-compliant list, currently 167 entries, should trigger enhanced due diligence. Compliance teams should cross-reference every new ESMA update against their existing counterparty lists. The 12 August update adds two new registered CASPs and removes one, each of which changes the compliance posture of any firm that had a relationship with those entities. For further context on how AML obligations follow EMT authorisations across different regulatory frameworks, the FATF DeFi guidance published earlier this year is instructive.
Practical Steps for Accounting Firms and CFOs
The ESMA register is a living document. Treating any single snapshot as a final reference is a compliance risk. The following actions are appropriate following the 12 August update.
Immediate counterparty review
Firms should pull the current ESMA register and cross-reference it against all crypto-asset counterparties, issuers, and CASPs in their client portfolios or treasury operations. Any entity that appeared on a previous register but is absent from the current one should be flagged, as the Altlift removal illustrates. Any token described by a counterparty as a MiCA-compliant EMT or ART should be verified against the register before that characterisation is accepted for accounting or compliance purposes.
Update client file documentation
Audit files for clients holding stablecoins should be updated to record the regulatory status of those tokens as at the balance sheet date. For a client holding a Dinaro-issued token after 12 August 2026, the file should note the EMT registration date, the supervising authority (Bank of Slovenia), and the applicable MiCA obligations. This documentation supports the auditor's assessment of credit risk and the appropriateness of the client's accounting treatment.
Review vendor capabilities for register integration
If your firm's digital asset accounting software does not already ingest ESMA register updates, raise this with your technology provider. The register is publicly available and machine-readable. Firms tracking MiCA licensing milestones across the EU know that the pace of new authorisations is accelerating. Manual tracking will not scale.
Watch the ART register
The ART register remaining empty is meaningful. It signals that no issuer has yet secured full authorisation for a token backed by a basket of assets. If a client is using a token that its counterparty describes as an ART, that description is currently unverifiable against the ESMA register, which is itself a compliance concern requiring escalation.
Frequently Asked Questions
What is the ESMA MiCA EMT register?
ESMA maintains a public register of all electronic money institutions authorised to issue electronic money tokens under MiCA. Each entry confirms that the issuer is licensed by a national competent authority within the EU and is subject to the capital, reserve, and redemption requirements set out in MiCA Title III. The register is updated on a rolling basis.
Is a token on the ESMA EMT register safer than an unregistered stablecoin?
From a regulatory and legal standpoint, yes. A MiCA EMT issuer must maintain a 1:1 liquid reserve, allow redemption at par on demand, and meet ongoing supervisory requirements. An unregistered stablecoin carries no equivalent legal guarantee. That said, accounting and audit teams should still assess the reserve composition disclosures published by the issuer, because registration is a necessary but not sufficient condition for a clean credit risk assessment.
What does the removal of Altlift from the CASP register mean for firms that used it?
Any firm that engaged Altlift as a regulated CASP counterparty should update its compliance and AML documentation to reflect that Altlift's authorisation notification was dated 30 June and it no longer appears on the register. Ongoing relationships, if any, should be reviewed against the firm's policy for engaging with unregistered entities. Enhanced due diligence documentation is advisable.
How often does ESMA update the MiCA registers?
ESMA updates the registers on a rolling basis as national competent authorities notify new authorisations or removals. There is no fixed weekly or monthly schedule. Firms should subscribe to ESMA's official register notifications or implement automated monitoring rather than relying on periodic manual checks.
Does the empty ART register mean no asset-referenced tokens are legally permitted in the EU?
It means no issuer currently holds full MiCA authorisation for an ART. Tokens that were in circulation before MiCA's transitional provisions expired may still be operating under national transitional arrangements, depending on the jurisdiction. Any token presented to a firm as an ART should be verified against both the ESMA register and applicable transitional rules in the relevant member state before it is accepted for treasury or settlement purposes.
Source: Cointelegraph