The designation arrives as Circle and the European Central Bank both push for changes to MiCA's reserve requirements. The regulation mandates that e-money token issuers hold at least 30% of reserve assets in commercial bank deposits, rising to 60% for significant tokens. Circle has argued that the 60% floor increases exposure to banking-sector credit and counterparty risk, citing the $3.3 billion in USDC reserves held at Silicon Valley Bank during its 2023 failure. The ECB and 27 national central banks have similarly called for the mandate's removal, favoring a risk-based approach scaled to each stablecoin's specific redemption profile.
ESMA's interim register listed 49 e-money token white papers from 24 issuers across 14 countries by late September 2026. Five issuers were credit institutions; the rest were electronic money institutions. Under MiCA, only a credit institution or an EMI may issue an e-money token; a CASP licence alone is insufficient.
The EBA's decision establishes the first live test of MiCA's dual-supervision framework for a systemically important stablecoin. Whether the reserve-composition rules survive the ongoing MiCA review will shape the operating model for every significant token that follows.
Sources: Source 1 · Source 2 · Source 3 · Source 4 · Source 5 · Source 6
