

Luxembourg continues to position itself at the forefront of financial innovation. A recent clarification from the CSSF regarding the Law of 17 December 2010 on undertakings for collective investment (UCITS) opens the door for a new type of fund distribution: stablecoin-based subscriptions.
In its updated FAQ (February 2026), the regulator clarified that UCITS funds may temporarily hold MiCAR-compliant e-money tokens when processing subscriptions or redemptions.
As the CSSF states: “For the sole purpose of processing subscriptions or redemptions, UCITS may also hold e-money tokens as defined in Article 3(1)(7) of MiCAR.” However, these tokens cannot remain in the portfolio: “Such e-money tokens shall be converted to bank deposits at sight or invested in eligible assets as soon as practicable". In practice, this means regulated stablecoins can now be used as settlement rails for UCITS fund flows.
Imagine a Luxembourg UCITS investing in global equities.
A retail investor holding EURC (Circle’s euro stablecoin) could subscribe to the fund directly from their crypto wallet:
The investor now holds shares of a regulated UCITS fund, while the subscription originated entirely on-chain.
This creates a bridge between crypto-native capital and traditional regulated investments.
With this regulatory clarification, fund issuers can combine:
Using Fume, asset managers and fund administrators can bring UCITS funds onchain, enabling investors to subscribe using compliant stablecoins while maintaining full regulatory compliance.
If you are exploring tokenized fund distribution or stablecoin subscriptions, Fume can help.
👉 Get in touch with the Fume team to learn how your UCITS fund can accept MiCAR-compliant stablecoins.
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