Polkadot launches no-issuer dotUSD: Why MiCA regulations require issuers

Polkadot launches non-issuer stablecoin dotUSD: Technical analysis and EU regulatory conflicts

Starting from October 8, 2026, Polkadot's main network has officially launched its own stablecoin dotUSD. This is a token that anchors the U.S. dollar and has no issuer. No company issues it, no bank holds reserves, and no regulator authorizes it. It is entirely governed by the holders of Internet Tokens DOT through the OpenGov voting system.

The timing of the release is awkward for investors in the European Union (EU). On the same day (October 8), the European Securities and Markets Authority (ESMA) issued an opinion directly targeting such tokens. This article will explain the technical principles of dotUSD, analyze why its structure conflicts with the EU crypto asset regulation MiCA, and the feasible paths German investors currently face.

dotUSD: stablecoins launched on the main network on October 8

stablecoins are crypto-assets whose prices are designed to track stable reference values (usually currencies such as the US dollar). The USDT and USDC are well-known examples: in these cases, there are companies behind them that support tokens, manage reserves and promise redemption.

dotUSD takes a different path. The release proposal clearly states that the token should be "issuer free" and run only through logic on the blockchain. Polkadot's own description calls it an "overcollateralized" anchored dollar stablecoin. "Overcollateralized" means that every token issued is backed by collateral assets that exceed its face value, thereby ensuring that fluctuations in the collateral assets do not immediately cause the token price to fall below the anchor value.

The large price database CoinGecko does not yet display the circulating supply of dotUSD. Although the token was listed under the stablecoin category, its price and supply remained zero the day after its release. Therefore, as of Thursday, it is not yet possible to measure the actual size of dotUSD with exact data.

Referendum 1944: How DOT governance determines the fate of stablecoins

At the legal and organizational levels, dotUSD relies on one vote. OpenGov Referendum 1944 is titled "dotUSD: Polkadot's Native stablecoin" and marked as executed after receiving approval. The proposal was submitted by the Polkadot Community Foundation, which made it clear that it would only assume an administrative role in the process.

OpenGov is Polkadot's voting process: Anyone holding DOT can make decisions on proposals, and approved proposals are executed by the chain itself. As a result, the responsibility for dotUSD falls on the ever-changing majority of token holders. This structure is technically consistent, but is a core regulatory issue, as shown in the section on MiCA below.

Peg Stability Module: The first phase of how to anchor dotUSD to the U.S. dollar

release is divided into two phases. The first phase looks different from what the term "native stablecoin" implies. In the first stage, users cast dotUSD at a one-to-one ratio through the so-called "Peg Stability Module", with USDT as collateral and a cap. The Peg Stability Module is a contract on the chain that provides a fixed exchange rate between two tokens, locking the price of a new token to the old token.

This means that dotUSD is relying on third-party stablecoins as support at the current stage. Holding dotUSD means taking part of the risk of the USDT reserves behind it. What stablecoins still offer by German providers and how they are different can be seen through our stablecoin comparison.

Overcollateralization along the Liquity v2 route: Phase 2 plans to use the DOT vault

Phase 2 aims to get tokens away from dependence on USDT. At that time, users will lock DOT in the vault and cast dotUSD at a ratio lower than the dollar value of the secured assets. The proposal gives an example mortgage rate of 150%: lock in secured assets worth US$1,000, and a maximum of approximately US$666 in dotUSD can be minted. The calculation example in the proposal uses a DOT price of $5 and therefore does not reflect current market conditions.

Liquidity v2 as a model: Stability pooling, clearing and redemption

The technical basis specified in the proposal is Liquidity v2and its stablecoin BOLD. This introduces price prediction machines to move the prices of collateralized assets into chains, stability pools to absorb low-mortgage positions, and clearing and redemption mechanisms. Liquidation here means that once the value of a position falls below the required ratio, its secured assets will be forcibly realized. For holders, this means that a sharp drop in DOT prices could lead to losses on locked secured assets without requiring the holder to take any action.

At this stage, U.S. dollar anchoring will be maintained through two mechanisms: arbitrage (traders eliminate deviations by redeeming tokens to DOT) and limited buffers of existing stablecoins. Both are market-dependent mechanisms. None of them create claims against counterparties.

E-money tokens (EMT) and ARTs: MiCA's authorization requirements for stablecoin issuance

The European Union Crypto Asset Markets Regulation (referred to as MiCA) will come into effect in 2024. It divides stablecoins into two categories: electronic currency tokens (EMTs), which refer to a single official currency; and asset reference tokens (ARTs), which point to a basket of assets or other value. According to the plan, tokens anchored to the U.S. dollar fall into the first category.

BaFin (the German Federal Financial Supervisory Authority) stipulates on its page on token issuance under MiCA who can issue such tokens. For e-money tokens, it is stipulated that only credit institutions or e-money institutions can issue them or apply for their listing. For asset reference tokens, regulators require prior authorization, citing MiCA Article 16(1)(a) in conjunction with Article 18. In both cases, a crypto-asset white paper must be submitted.

Each responsibility presupposes an entity capable of fulfilling the responsibility: a licensed institution, a regulatory address, and someone responsible for the white paper. This is exactly what dotUSD leaves blank in its own description. A token without an issuer cannot meet the requirements placed on the issuer. This is not an oversight, but a result of the way it is constructed.

ESMA opinion on October 8: Clean up non-compliant stablecoins within three months

On the day of the dotUSD release, ESMA strengthened its position on such tokens. In its opinion of October 8, 2026 (reference number ESMA75-113276571-1742), the bureau wrote that crypto asset service providers authorized by MiCA should stop providing services related to non-MiCA-compliant stablecoins to customers within the EU.

适用范围很广。法规中的所有加密服务均涵盖在内，单独或组合包括：交易平台、兑换、订单执行、托管、投资组合管理和转账。国家监管机构应检查企业是否不持有此类代币、不列出它们且不为客户访问它们。预计将实施技术、合同和组织控制措施，包括阻止客户建立或增加现有头寸的措施。

对于遗留持仓，意见规定了截止日期：国家当局应在意见发布后不超过三个月内要求清仓，并尽早进行。在此期间可能继续的活动严格限制为清算、兑换、提取、转账或托管此类资产所需的必要活动。即使这些活动也需限时、基于风险并进行密切监控。

无发行方，无赎回权：持有者的风险所在

对于背后有公司的稳定币，当锚定失效时，持有者有一个可以求助的地址。而对于 dotUSD，则没有。根据提案，美元锚定依赖于套利和受限的稳定币缓冲，即依赖于市场参与者的行为和程序代码。

随之而来的实际后果是：如果你持有 dotUSD 并看到价格偏离一美元，你将没有合同交易对手可以要求其支付面值。你可以在市场上出售代币，或者在第二阶段通过链机制将其赎回为 DOT。这两者都取决于当时的流动性和机制是否正常运作。

There are also risks in the first stage. As long as the backer consists of USDT, dotUSD hangs above a token, and the availability of that token with MiCA-regulated providers in the EU is currently shrinking. Therefore, redemption through Germany's supervised platforms is not a reliable exit route.

DOT quote US$1.15: Trading Day Data

The response from the online token itself was relatively calm, but better than the overall market. Early Thursday, DOT quoted $1.15, 2.85% higher than 24 hours earlier. The range for the day was $1.01 to $1.15, with prices at the edge of the upper limit. The market value is approximately US$1.96 billion, ranking 51st in the overall market. It fell 3.28% in the past seven days and 4.39% in the past 30 days. All data comes from CoinGecko.

This increase occurred in weak markets. At the same time, the total cryptocurrency market value was approximately US$2.78 trillion, down 4.69% from the previous day. Bitcoin is quoted just under $82,000. DOT's rise was remarkable when broad segments of the market weakened, but available data cannot attribute it solely to the launch of stablecoins. The project description anticipates that demand for dotUSD in the second phase will translate into direct demand for DOT as the secured assets will be withdrawn from free circulation. But this is just an expectation, not a measurement.

Purchase routes and custody in Germany: The situation of regulated providers

In practice, the situation for German investors is as follows: Given ESMA's position, access to dotUSD through EU-supervised platforms is not expected as long as the token does not meet regulatory requirements. If you still want to hold, you need to go beyond the regulatory framework, which is self-custody by using your own wallet on the Polkadot chain.

Self-escrow: Importance of keys

In self-escrow mode, the holder assumes responsibility for the private key. There are no offices that can reset lost passwords and there are no deposit guarantees. Hardware wallets keep keys on a separate device, separate from your computer or smartphone. In addition, there is the second stage of vault risk, in which a decline in DOT prices may impact locked up secured assets.

Holding periods and taxes: How Germany taxes gains from stablecoin transactions

In Germany, crypto assets are considered "other assets." Gains sold within one year after purchase are subject to tax under Section 23 of the Income Tax Act; after one year they are exempt. There is an exemption threshold of € 1,000 per year for private disposals; once exceeded, all proceeds are subject to tax.

将一种稳定币兑换为另一种加密资产被视为税务上的处置行为，即使美元价值保持不变。在第一阶段以 USDT 为抵押铸造 dotUSD 因此会触发税务相关交易。来自保险库的收入需要单独评估。此概述不构成税务建议，且对无发行方代币的处理尚未最终确定；对于大额资金，建议咨询税务顾问。

结论：无授权发行方，接入渠道狭窄

通过 dotUSD，Polkadot 发布了一种在技术上描述清晰但在监管方面尚未完善的产品。对于德国投资者而言，第一天变化不大，因为通过受监督提供商的路径仍然受阻。现在值得做三件事：

• 审查你的提供商：检查你的平台是否拥有 MiCA 许可证以及它仍列出哪些稳定币。为了进行比较，概览可在受监管的加密交易所中找到。
• 梳理现有的稳定币头寸：ESMA 的三个月期限适用于服务提供商处的遗留持仓，而非你自己钱包中的代币。哪种托管解决方案合适，可查看硬件钱包比较。
• 记录每次兑换：从一种稳定币兑换为另一种稳定币是税务相关事件。税务工具或投资组合跟踪器会在报税前记录日期、价格和持有期。

(As of October 9, 2026. This article does not constitute investment advice. Price and fee structures are subject to change; please check terms with your provider before purchasing.)