The European System of Central Banks (ESCB) released on September 22, 2026 its response to the European Commission’s consultation on the Markets in Crypto-Assets (MiCA) regulation. This marks the institution’s first official position on stablecoin reserve requirements, with a direct challenge to the threshold imposed on issuers deemed “significant.”
🔑 Key takeaways
- The ESCB demands the removal of the 60% bank deposit rule for significant stablecoin issuers.
- It proposes replacing it with a minimum share of assets maturing in 1 to 5 business days.
- The institution calls for EU-level supervision of large crypto-asset service providers.
- As of August 8, 2026, ESMA lists 22 authorized electronic money token issuers in the EU.
- The ESCB flags persistent access of non-compliant crypto firms to European clients.
The ESCB’s opposition to the 60% rule
In its opinion published on September 22, 2026, the ESCB — which brings together the European Central Bank (ECB) and the 27 national central banks — directly targets the MiCA article requiring issuers of significant stablecoins to hold at least 60% of their reserves as bank deposits. The institution considers the requirement counterproductive: it exposes lending institutions to stablecoin market fluctuations and to potentially less stable deposits than banks’ traditional funding base.
“Central banks have warned that such requirements could expose lending institutions to stablecoin market fluctuations and to less stable deposits.”
Investing.com, citing the ESCB response
To meet the liquidity objective without weakening banks, the ESCB proposes substituting the 60% threshold with a minimum share of reserves held in assets maturing between one and five business days. The approach aims to guarantee token convertibility into fiat currency while reducing the degree of interdependence between bank balance sheets and stablecoin-driven flows.
Current MiCA thresholds and triggers
MiCA distinguishes two regimes for electronic money tokens (EMTs). “Ordinary” issuers must hold at least 30% of their reserves as bank deposits; those classified as “significant” by the European Banking Authority (EBA) see that floor raised to 60%. The significant status is triggered, among other criteria, from 10 million holders or €5 billion issued.
As of August 8, 2026, the European Securities and Markets Authority (ESMA) registry listed 22 authorized issuers in the Union, including Circle (USDC and EURC), Société Générale-FORGE (EURCV) and Banking Circle (EURI). None has yet been classified as significant, but the gap between the two regimes remains a major regulatory friction point.
| MiCA regime | Bank deposit floor | Trigger threshold |
|---|---|---|
| Ordinary EMT | 30% | Standard national authorization |
| Significant EMT | 60% | ≥ 10M holders or ≥ €5B issued |
| ESCB proposal | Unspecified | Quotas of assets with 1–5 day maturity |
Toward EU-level supervision of large players?
Beyond reserves, the ESCB contests the current supervisory architecture. MiCA entrusts national authorities with the authorization and oversight of all crypto-asset service providers (CASPs), regardless of size. The ESCB calls for a European-level layer for entities belonging to multinational groups or providing significant cross-border services, in order to limit regulatory arbitrage between member states.
The argument is twofold. First, the oligopolistic position of large global platforms creates a systemic risk that no national regulator can contain alone. Second, current fragmentation holds back the emergence of an integrated European market for crypto services. The Commission’s consultation fits squarely within this reflection, which runs until the end of 2026.
Meanwhile, decentralized finance (DeFi) protocols are adapting to the framework. Aave Labs obtained a MiCAR license through its subsidiary Push Virtual Assets in November 2025, a first that could foreshadow a closer alignment between DeFi and formal supervision.
The transatlantic debate over stablecoin yields
The European-American disagreement does not only concern liquidity buffers: it also covers stablecoin remuneration. In the United States, the White House Council of Economic Advisers (CEA) quantified the impact of a yield ban. If the stablecoin market reached 10% of bank deposits, bank credit would only increase by $11 billion to $14 billion, or roughly 0.1% of outstanding loans. Under a more realistic scenario (1.7% of deposits, around $300 billion), the credit uplift would be limited to $2.1 billion.
These figures are disputed by the American Bankers Association and the Independent Community Bankers of America, which argue the substitution risk is much larger. The debate remains open, but it fuels the ECB’s concerns over the impact of stablecoins on banking system stability.
Volumes and competition over yields
Globally, Tether’s USDT weighs around $183 billion and Circle’s USDC some $75 billion. These amounts remain modest against total bank deposits, yet they are enough to worry traditional institutions. In France, the Livret A and LDDS savings accounts yield 1.7% since August 1, 2026. By comparison, Coinbase offers roughly 3.5% on USDC held on its platform for Coinbase One members, and USDC lending via Fluid on Base shows up to 4.8% annually.
MiCA, however, prohibits remunerating electronic money tokens in the European Economic Area (EEA). Coinbase removed its USDC rewards in the EEA as early as December 1, 2024. For EU residents, only DeFi currently offers a way to earn yield on stablecoins, a further attractiveness factor for protocols such as Aave or Morpho.
The ECB remains committed to banking resilience
The ESCB’s position does not signal a general loosening of banking regulation. ECB Supervisory Board Chair Claudia Buch recently warned against any excessive weakening of European rules. She stressed that well-capitalized institutions are better equipped to keep financing the economy during periods of stress, and that European capital requirements remain broadly in line with international standards.
“Well-capitalized institutions are better equipped to keep financing the economy during periods of stress.”
Claudia Buch, Chair of the ECB Supervisory Board
This balancing act — adjusting the stablecoin framework without lowering banking standards — captures Frankfurt’s prudential strategy.
Enforcement challenges under MiCA
The ESCB also flags a blind spot in the regulation: the continued access of non-compliant crypto firms to European clients. Despite MiCA’s full entry into force, certain non-European providers still serve EU customers without local authorization, raising investor protection and unfair competition concerns. The European regulator will likely need to strengthen cooperation mechanisms with third-country peers for the framework to be fully effective.
Conclusion: toward a MiCA “2.0”?
The ESCB’s response sends a strong political signal: the euro area’s monetary authority is not just implementing MiCA, it wants to redraw some of its parameters. Removing the 60% bank deposit rule, combined with a short-term liquid asset quota, would aim to protect bank balance sheets without stifling financial innovation. If the Commission follows this direction, a “MiCA 2.0” could emerge by 2027, paired with a European supervisory layer for large crypto players.
For issuers like Circle or Société Générale-FORGE, the stakes are high: lighter reserve constraints would optimize treasury management while preserving user trust. For European banks, the main benefit would be reduced exposure to stablecoin market swings. The open question is whether the final compromise will satisfy both camps, or whether regulatory fragmentation between the EU and the United States will continue to shape the global market.
Sources
- Cryptoast – ECB: EU central banks oppose the bank deposit rule for stablecoins
- Investing.com – ECB opposes bank deposit requirements for stablecoin reserves
- Banque de France – Governance and European ecosystem
- Le Revenu – ECB: excessive loosening of banking rules
- French Council of Economic Analysis – Note 065 on stablecoins
- Banque centrale du Luxembourg – ECB explainers
This article is for informational and educational purposes only. It does not constitute investment advice. Do your own research (DYOR) before making any decision.
