Brussels and Washington’s stablecoin rulebooks edge closer as the ECB targets MiCA’s deposit rule

EU central banks ask Brussels to drop MiCA’s bank-deposit rule

The European Central Bank and the European System of Central Banks (ESCB) formally asked the European Commission on 22 September 2026 to delete MiCA’s rule forcing stablecoin issuers to hold up to 60% of reserves as bank deposits. The recommendation appears in the ESCB’s consultation response to the Commission’s review of the Markets in Crypto-Assets Regulation (MiCA).

Under the current framework, issuers of non-significant tokens must keep at least 30% of reserves in bank deposits, rising to 60% for tokens classified as significant. The ESCB argues the mandate creates a direct link between issuers and credit institutions that could expose banks to liquidity problems if a stablecoin run forced rapid withdrawals. It proposes replacing percentage-based deposits with liquidity thresholds, requiring reserve assets to mature within one to five working days, and pointed to overnight reverse repos and short-term sovereign bonds as suitable instruments.

Two rulebooks for one market

The proposal would move the EU closer to the model in the United States. The GENIUS Act regulates stablecoin reserves without the rigid deposit-percentage requirements MiCA imposes. If the Commission adopts the ESCB’s recommendation, the practical difference between the EU and US rulebooks narrows to maturity-based liquidity floors rather than where the money must sit, and issuers operating in both markets would face less divergence in how they structure reserves.

The ESCB did not put specific percentages on its own proposal. It cited the European Banking Authority’s 2024 draft rules as reference, which required significant stablecoins to hold at least 40% of reserves in assets maturing within one working day and 60% within five working days, with 20% and 30% thresholds respectively for non-significant tokens. Those figures are the EBA’s, not necessarily what the central banks propose.

A rare regulator-industry alignment

The ESCB’s argument echoes one Tether’s chief executive has made since 2024. Paolo Ardoino said on X that Europe’s central banks now want Brussels to delete the very clause over which Tether refused an EU licence. That refusal is his own characterisation, not an independently verified filing. Ardoino warned in an October 2024 interview that a stablecoin holding €10 billion in reserves, €6 billion of it in bank deposits, would be left with just €600 million if the bank lent out 90%.

The risks run both ways, the central banks argued. They cited the March 2023 collapse of Silicon Valley Bank, which triggered a run on Circle’s USDC after Circle disclosed $3.3 billion of reserves held at the bank. The ESCB also warned of material challenges enforcing MiCA, saying non-compliant crypto companies operating outside EU borders can still reach EU customers, and treated the reserve question in macro-financial terms without singling out any issuer.

The response is a recommendation to the Commission’s MiCA review, not a change in law, and neither the ECB nor the Commission has given a timeline for adopting the recommendation. MiCA’s stablecoin provisions became fully applicable during 2024 and 2025, making Europe the first major jurisdiction with a full crypto-asset framework.