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EBA Classifies USDC as First Significant EMT Under MiCA


Key points

  • The EBA has classified Circle's USDC as the first significant EMT under MiCA, triggering a dual-supervision regime alongside France's ACPR.
  • Significant EMT status raises the commercial bank reserve requirement from 30% to 60% of total reserves, and minimum capital from 2% to 3%.
  • The EBA did not disclose which of MiCA's seven significance criteria USDC satisfied; any three of the seven are sufficient to trigger classification.
  • The ESCB has proposed replacing the bank-deposit floor with minimum daily and weekly liquidity buckets in the ongoing MiCA 2 consultation, citing systemic outflow risk.
  • The Silicon Valley Bank collapse, which caused USDC to lose its peg, is cited as evidence that reserve concentration risk runs in both directions between stablecoins and banks.

The European Banking Authority (EBA) has designated Circle‘s USDC as the first electronic money token (EMT) to meet the threshold for significance under the Markets in Crypto-Assets (MiCA) framework. Circle’s French subsidiary, which previously answered only to the French regulator ACPR, now faces dual supervision, with the EBA assuming direct responsibility for own funds, reserve assets, liquidity requirements, and recovery and redemption planning.

The practical consequence is an immediate tightening of reserve and capital rules. Significant EMTs must hold 60% of reserves at commercial banks rather than the 30% floor that applies to standard issuers, and minimum capital rises from 2% to 3% of reserves. For a dollar-denominated token like USDC, sourcing banks willing to absorb large USD deposits in the European market is a non-trivial operational constraint, and the article identifies this as a meaningful cost burden for Circle.

The 60% bank-deposit floor may, however, prove short-lived. The European System of Central Banks (ESCB) has expressed concern that a stablecoin run could trigger material outflows from the banking system, a risk the Silicon Valley Bank episode illustrated from the opposite direction when USDC itself temporarily lost its peg. In the ongoing MiCA 2 consultation, the ESCB has proposed scrapping the deposit floor entirely in favour of minimum daily and weekly liquidity buckets, with a 40% daily floor for significant stablecoins and 20% for others, drawing on draft EBA liquidity standards. Operators building reserve or custody infrastructure around the current 60% rule should treat that figure as potentially transitional rather than settled.

Original source

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