The European Commission’s consultation on the MiCA crypto framework closes Tuesday at 23:59 CEST, and the most contested submission so far comes from Europe’s own central banks, who want the rule forcing stablecoin issuers to hold 30 to 60 percent of reserves as bank deposits scrapped.
The European System of Central Banks filed its response on September 22. In it, the eurozone’s monetary authorities argue that the deposit requirement, meant to keep stablecoin reserves inside the regulated banking system, creates concentration risk without adding much protection. Issuers parking billions at a handful of banks could strain those banks in a redemption crisis, the central banks say, and the money would be safer in short-dated government debt and repo markets instead.
Under current MiCA rules, significant stablecoin issuers must hold 60 percent of reserves as bank deposits, with smaller issuers at 30 percent. The requirement was written when policymakers worried about issuers running opaque reserve portfolios. Critics, including several large issuers, have called it a subsidy for banks that earn spread on stablecoin float while adding a failure point the sector does not need. The debate has run since the rules were drafted, but the ECB’s formal entry into it changes the weight on each side.
Multi-issuance models in the crosshairs
The central banks went further than the reserve question. They backed the European Systemic Risk Board’s position that multi-issuance models, where a global stablecoin firm treats tokens issued inside the EU as interchangeable with those issued elsewhere, are not permitted under the current rules. Several major issuers have structured their businesses this way, and the ESRB has warned the arrangement could let problems outside the bloc propagate into European holders’ tokens without any EU supervisor able to intervene.
The submission also flagged uneven enforcement across member states. MiCA took full effect at the end of 2024, and national authorities have interpreted parts of the framework differently, which issuers say makes compliance planning across the single market difficult. The Commission’s review is expected to address supervisory consistency alongside the reserve rules. Firms have pointed to cases where one regulator approved a product structure that another member state’s authority later challenged, leaving the issuer with legal exposure in a market it had already launched in.
What the review covers
| Area | Status |
|---|---|
| Stablecoin reserve composition | ECB wants bank deposit mandate dropped |
| Multi-issuance models | ESRB says current rules already prohibit them |
| Supervisory consistency | Issuers report divergent national interpretations |
| Consultation deadline | Sept. 30, 23:59 CEST |
A market that outgrew its rules
The stablecoin sector the review is examining looks little like the one MiCA was drafted for. Total stablecoin market capitalization sits near $292 billion, and dollar tokens hold more than 99 percent of it. Europe’s own euro-denominated issuers remain marginal, which has fed a running complaint from European fintechs that the framework protects a market their region barely participates in.
New entrants keep arriving anyway. AllUnity, the German issuer behind the EURAU euro stablecoin, launched a MiCA-regulated dollar token this week on six blockchains. Germany’s BaFin has licensed more euro issuers than any other member state, yet euro tokens still hold a sliver of global circulation. The Commission’s own staff papers have acknowledged the asymmetry between strict local rules and a dollar-dominated global market.
The United States moved in the opposite direction last year with the GENIUS Act, which set a federal regime for payment stablecoins with its own reserve and redemption requirements. US regulators have since proposed detailed liquidity rules for issuers, including minimum daily liquid asset percentages and concentration limits. European issuers now face a compliance patchwork across two major regimes, and several have said the deposit rule is the requirement that most distorts their economics. Compliance teams at larger issuers have described running parallel reserve structures to satisfy both frameworks, with separate custody arrangements and reporting calendars for each.
The UK adds pressure
The UK finalized its own crypto framework this week and opened licensing applications on September 30, cutting stablecoin issuer capital requirements from 2 percent to 1 percent after industry pushback. London is positioning itself as the lighter-touch alternative while Brussels reviews its rulebook, and several firms have said jurisdiction choice for their EU-facing operations now depends on what comes out of this review.
After the consultation closes, Commission staff will summarize submissions and draft proposed amendments, a process that typically takes months. Any change to the reserve requirement would then need to pass the Council and Parliament, where the banking lobby has defended the deposit rule as a financial stability safeguard. The ECB’s public intervention gives the amendment effort unusual high-level backing, but it also sets up a direct fight with institutions that profit from the current arrangement. European banks have earned meaningful fee income from stablecoin reserve deposits, and their associations are expected to file in defense of the status quo before the deadline passes.
Issuers, banks and industry groups all filed before the deadline, and the volume of responses itself will shape the political appetite for amendment. The one point close to consensus across submissions is that the current reserve rules, whatever their intent, were designed for a smaller and simpler market than the one they now govern. Whether the Commission agrees that the ECB has the right answer, or merely that the question deserves reopening, will determine whether Europe’s stablecoin rules change in 2027 or stay as written.