Europe’s central banks are asking Brussels to rethink how MiCA regulates stablecoin reserves.
The European System of Central Banks—comprising the ECB and the 27 EU national central banks—argues that forcing stablecoin issuers to hold a fixed share of reserves as bank deposits can itself create financial-stability risk.
The central banks want reserve regulation to focus more on liquidity and maturity than on a fixed bank-deposit percentage.
Current MiCA rule
Under the current MiCA framework, stablecoin issuers are required to hold a minimum share of reserve assets as bank deposits.
Current reporting describes the thresholds as:
- 30% for non-significant tokens;
- 60% for significant stablecoins.
The rule is designed to ensure ready liquidity and protect redemption.
Why the ESCB wants the deposit floor removed
The central banks argue that mandatory stablecoin deposits can change bank funding structures.
A large issuer can collect money from users and place a large share into one or more banks.
That bank funding may look like deposits, but it can be more volatile than ordinary retail deposits because a stablecoin run can cause the issuer to withdraw cash rapidly.
In other words, the rule can transfer stablecoin-run risk into bank funding.
Proposed replacement: maturity-based liquidity
Instead of a fixed bank-deposit percentage, the ESCB recommends requiring a minimum share of reserves in assets that mature within:
- one working day;
- five working days.
That shifts the regulatory objective from: “how much is in a bank?”
to:
“how much can become cash fast enough to satisfy redemptions?”
Short-dated sovereign assets and high-quality liquid instruments could potentially play a larger role under such a model.
This is not deregulation
Removing a bank-deposit floor does not necessarily mean lower reserve quality.
A maturity-based framework can be stricter about liquidity while allowing issuers to diversify away from concentrated bank deposits.
The key question is calibration:
- what percentage must mature in one day?
- what percentage within five days?
- what assets qualify?
- how are stress redemptions modeled?
Those details are not yet final legislation.
Bank-run versus stablecoin-run contagion
The ESCB’s concern runs in both directions.
A bank failure can threaten a stablecoin peg if issuer reserves are trapped at that bank.
A stablecoin run can threaten a bank if an issuer rapidly withdraws a large deposit balance.
The March 2023 USDC/Silicon Valley Bank episode is a historical example of why concentrated reserve banking can transmit risk.
Multi-issuance stablecoins
The central banks also raise concerns about multi-issuance models in which tokens issued inside and outside the EU are treated as interchangeable.
The risk is that EU reserve assets could be used to satisfy redemption demands from token holders outside the bloc.
During stress, EU-based reserves might therefore be insufficient for both:
- EU-issued liabilities;
- interchangeable third-country liabilities.
Current MiCA treatment is restrictive toward such arrangements.
The ESCB says any future permission would need a comprehensive safeguards framework, including assessment of third-country regulatory equivalence.
Stablecoin yield: broader restrictions under discussion
Current reporting on the ESCB’s consultation response says the central banks also want MiCA’s prohibition on stablecoin interest/yield to extend beyond directly regulated issuer/CASP payments.
The concern is that stablecoins can generate economic yield indirectly through:
- lending;
- borrowing;
- staking;
- liquidity-mining incentives;
- bundled fee reductions or loyalty benefits.
If stablecoin yield can be recreated through an adjacent product, the direct interest ban can become easy to circumvent.
The policy recommendation therefore points toward regulation based on economic substance, not just product labels.
Lending, borrowing and staking may enter the perimeter
The broader recommendation also argues for EU-level regulation of crypto lending, borrowing and staking.
That could materially affect:
- centralized earn products;
- stablecoin yield accounts;
- custodial staking;
- lending desks;
- DeFi-facing interfaces.
However, this is a policy recommendation under review, not an immediate new authorization requirement.
Enforcement gap
The ESCB also says European regulators face material challenges enforcing MiCA while non-compliant crypto businesses remain accessible to EU users.
That matters because a strict reserve framework has less effect if consumers can easily access offshore products outside the licensed perimeter.
The consultation response therefore combines:
- prudential reserve design;
- product-perimeter questions;
- cross-border enforcement.
What remains law today
The current MiCA reserve requirements have not been replaced by this consultation response.
Issuers must continue complying with existing rules until:
- the European Commission proposes changes;
- legislation or delegated rules are adopted;
- effective dates are reached.
CEXVia therefore classifies the event as Medium regulatory change risk, not immediate non-compliance risk.
Impact on major stablecoin issuers
If adopted, the proposed framework could affect:
- reserve portfolio composition;
- bank counterparties;
- issuer profitability;
- short-term sovereign demand;
- liquidity management;
- yield-product structures;
- EU/non-EU issuance models.
The impact could differ materially between euro stablecoins and global dollar stablecoins.
Evidence Status
Confirmed / ESCB Position + Major-Media Reporting
- ESCB recommends dropping fixed bank-deposit reserve requirement.
- Current 30%/60% thresholds remain the baseline under MiCA.
- Recommended replacement focuses on assets maturing within one/five working days.
- Multi-issuance risk is highlighted.
- MiCA enforcement challenges are highlighted.
Reported From Consultation Response
- Broader stablecoin-yield restriction extending to lending/borrowing/staking and similar structures.
- Recommendation for EU-level treatment of lending, borrowing and staking.
Not Yet Law
- Final reserve percentages.
- New qualifying-asset list.
- Expanded yield ban.
- New lending/staking authorization requirements.
Risk Assessment
Medium regulatory / reserve-management / product-design risk.
The recommendations are not immediately binding, but if translated into legislation they can reshape how EU stablecoins hold reserves and how exchanges/protocols offer stablecoin yield.
What to Watch Next
European Commission response, MiCA review report, legislative proposal, EBA liquidity standards, ESMA enforcement changes, issuer lobbying and changes to stablecoin yield products.
FAQ
Has MiCA already removed the 30%/60% bank-deposit requirement?
No.
What does the ESCB want instead?
A liquidity framework based on a minimum share of reserves maturing within one and five working days.
Why do central banks dislike large stablecoin bank deposits?
They can replace sticky retail funding with deposits that may leave quickly during a stablecoin run.
Is stablecoin yield already banned everywhere in DeFi?
No. The central banks are recommending broader treatment; the proposed extension is not yet law.
What is multi-issuance risk?
EU and non-EU versions of the same stablecoin can create claims on the same effective reserve pool during stress.
Does this affect exchanges?
Potentially. Stablecoin earn, lending, staking and custody products could face a wider regulatory perimeter if the recommendations become law.