MiCA Article 36 governs how stablecoin issuers must structure their reserve of assets. The rule splits reserves into two buckets, cash bank deposits and other liquid assets. Under current requirements, issuers must hold at least 30% of reserves as bank deposits. That threshold jumps to 60% for “significant” stablecoins, tokens designated as systemically important under MiCA. Circle’s EURC and USDC currently sit among the MiCA-authorized tokens subject to this framework. The rule aimed to protect users by keeping issuer funds inside regulated, insured banking channels.
🇪🇺 BREAKING: Europe’s central banking system moves to expand the regulatory framework for tokenized finance.
— Generation Infinity (@Genfinity) September 22, 2026
In its new response to the European Commission’s MiCAR review, the European System of Central Banks lays out a broader framework covering tokenized deposits, stablecoins,… pic.twitter.com/7LzHtGFmgS
Why the ESCB Wants It Gone
On September 22, the European System of Central Banks published its response to the European Commission’s MiCA review. All 27 EU national central banks joined the ECB in that response. Together, they called on Brussels to remove the fixed bank-deposit requirement entirely. The central banks argue the rule creates a direct link between stablecoin issuers and credit institutions. That link becomes dangerous during a stablecoin run, when holders rush to redeem tokens for cash. A sudden redemption wave would force issuers to withdraw deposits from banks just as quickly. As a result, banks could face liquidity strain from crypto market stress, not from their own lending decisions. The ESCB effectively wants to stop stablecoin volatility from spilling into the traditional banking system.
The Liquidity-Based Alternative
Instead of a bank-deposit floor, the ESCB wants MiCA to lean on liquidity timing. Reserves would need to mature within short, fixed windows rather than sit in specific account types. The European Banking Authority already drafted technical standards along these lines back in 2024. Under that draft, significant stablecoins would hold at least 40% of reserves in assets maturing within one working day. A further 60% would need to mature within five working days. Non-significant stablecoins would face lighter thresholds, 20% and 30% respectively. The ESCB pointed to overnight reverse repurchase agreements and short-term sovereign bonds as suitable instruments. These assets can convert to cash quickly without relying on a single bank’s balance sheet. Consequently, issuers could meet redemption demand without triggering deposit runs at their banking partners.
A Wider Push for Tokenized Finance
The reserve rule change sits inside a broader ESCB response covering tokenized finance across the EU. The central banks positioned tokenized central bank money as the anchor for future wholesale settlement. Two ECB-led initiatives, Pontes and Appia, support that vision directly. Pontes went live on September 21, letting banks settle tokenized asset transactions in central bank money. Thirteen banks and four DLT operators already connected to the platform at launch. Appia, meanwhile, is building a longer-term blueprint for an integrated tokenized financial ecosystem by 2028. The ESCB also framed tokenized deposits as the preferred private-money instrument for these markets. Notably, the central banks argued stablecoins remain less suitable than tokenized deposits for large-scale wholesale settlement. They cited concerns about maintaining a stable value, scaling safely, and avoiding fragmented liquidity pools.
Guardrails the ESCB Wants to Keep
The ESCB isn’t asking for a lighter touch across the board. It explicitly backed keeping the ban on paying interest, or remuneration, to stablecoin holders. That ban currently stops issuers from competing directly with bank deposits on yield. The central banks also flagged workarounds that could undermine the ban indirectly. Lending, staking, and decentralized finance structures could all let issuers offer yield-like returns informally. As a result, the ESCB called for EU-wide rules treating crypto lending, borrowing, and staking based on their economic function. That approach would apply consistent rules regardless of the underlying technology used. The central banks additionally pushed for harmonized property, corporate, and insolvency law across member states. Fragmented national rules, they warned, could limit the scalability of tokenized markets going forward.
A Small but Fast-Growing Market
The debate touches a market that remains small relative to the dollar-denominated stablecoin sector. The euro stablecoin market sat at roughly $887 million by the first quarter of 2026. Circle’s EURC leads that market, holding about 41% of total euro stablecoin capitalization. Roughly a dozen issuers have secured MiCA authorization across countries including France, Germany, and Luxembourg. Tether, by contrast, does not appear on the ESMA register of authorized tokens. Its grandfathering period under MiCA closed on July 1, 2026, cutting USDT off from licensed EU venues. That dynamic gives MiCA-compliant issuers like Circle a clear regulatory advantage inside the bloc. Any change to the reserve rules would shape how these issuers compete going forward.
What Happens Next
The ESCB’s response feeds directly into the European Commission’s ongoing MiCA review process. The Commission will weigh the central banks’ input alongside feedback from industry and other regulators. Any formal rule change would still need to move through the EU’s standard legislative process. For now, the 30% and 60% bank-deposit thresholds remain in force under Article 36. However, the direction from Europe’s entire central banking system is now clear and unified. Regulators want stablecoin liquidity tied to asset maturity, not to deposit relationships with individual banks. That shift could reshape how issuers structure reserves well beyond the euro area itself.
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