FRANKFURT, September 23, 2026
The European Central Bank and EU national central banks proposed September 22 replacing MiCA’s stablecoin bank-deposit floors, including the 60% requirement for significant tokens, with liquidity tests as Europe reassesses how digital-money reserves expose banks to sudden withdrawals.
The European System of Central Banks submitted its recommendations to the European Commission’s review of the Markets in Crypto-Assets Regulation. The document proposes changes to reserve management; it does not change the law.
In CoinGecko’s September 23 snapshot at 10:24 UTC, USDT had a market capitalization of about $183.44 billion and USDC about $75.12 billion. Both traded near $1. These global figures indicate the scale of the market, not the amount of reserves subject to EU requirements.
The central banks’ consultation response argues that mandatory bank placements can transmit a stablecoin run into bank funding stress. It favors minimum proportions available within one and five working days, with final calibration requiring further analysis.
The issue has a concrete precedent. In March 2023, Circle disclosed $3.3 billion of USDC reserves at Silicon Valley Bank. That exposure represented about 8% of the token’s backing, showing how uncertainty over one reserve bank could affect a widely traded stablecoin.
Bitcoin
BTCSource: CoinGecko. Daily UTC observations plus the September 23 reading at 10:25 UTC. Bitcoin supplies wider crypto-market context; this chart does not measure stablecoin reserve liquidity.
MiCA liquidity tests would measure time, not bank balances
The EBA’s draft technical standards distinguish deposit requirements from maturity requirements. The former specify where reserves sit. The latter measure how quickly assets mature, deposits can be withdrawn or reverse repurchase agreements can be terminated.
For significant tokens referencing official currencies, the draft sets a 40% daily liquidity threshold and a 60% weekly threshold. For tokens not deemed significant, the corresponding figures are 20% and 30%. The five-working-day calculation includes the daily portion; the two percentages are not added together.
Consider a hypothetical issuer with €1 billion of reserves. A 40% daily threshold would mean €400 million available within one working day. A 60% weekly threshold would mean €600 million within five working days, including that first €400 million. It would not require €1 billion in two separate liquidity pools.
Nor does a five-day reserve calculation automatically give an issuer five days to delay every redemption. It describes the assets supporting payments, rather than a new customer withdrawal policy. The draft also addresses the alignment of reserve currencies and redemption obligations.
The distinction is central to the proposal: removing a prescribed bank allocation would not mean removing backing or liquidity requirements. An issuer could face tighter scrutiny of when its assets become cash even if it gains flexibility over where those assets are held.
That debate is separate from the ECB’s newly launched Pontes settlement service. Pontes concerns settling tokenized-market transactions in central bank money. This consultation concerns the reserves supporting privately issued tokens, a different form of money with different claims and risks.
USDC’s SVB exposure shows the reserve-bank risk
Circle’s March 2023 update said its SVB deposit would become fully available after US authorities announced depositor protection. At that point, Circle described reserves as 77% short-dated US Treasury bills and 23% cash, illustrating that even a mostly securities-backed token retained bank exposure.
The company also announced new banking arrangements for minting and redemption. The episode connects two operational questions: whether reserve assets are sufficient in value, and whether the issuer can actually move funds when holders request repayment. A stable market price does not independently answer either question.
The EBA’s December 2025 risk assessment separately identified concentration risk when a small number of stablecoin issuers place large reserves with a limited group of banks. Rapid withdrawals could leave those banks with funding gaps.
The report also notes an asymmetry: reserve concentration limits apply to an issuer’s exposure to a bank, while a bank can accept deposits from multiple issuers. Several individually diversified reserve portfolios could therefore still leave one bank exposed to withdrawals across the stablecoin sector.
The EBA identifies another possible transmission channel through sovereign bonds. Issuers selling debt quickly to raise redemption cash could affect bond yields and, indirectly, banks holding those securities. Shifting reserves away from deposits would consequently change the mix of exposures rather than eliminate every connection to traditional finance.
For an issuer, reducing reliance on one bank may address one vulnerability while leaving others to manage. A portfolio still needs reliable custody, payment access and assets that can fund redemptions. Diversification and liquidity therefore answer related but separate questions about the backing.
The current reform debate should not be read as evidence that a named European bank is experiencing a run. The central banks are discussing how rules should handle potential stress. Neither the consultation response nor the market snapshot establishes a new stablecoin loss event.
Stablecoin licensing and yield limits remain separate
The ESCB also favors retaining the interest prohibition and addressing arrangements that reproduce yield through other services. Greater reserve flexibility is therefore only one part of its position, rather than a general relaxation of stablecoin oversight.
MiCA Article 50 already prohibits e-money-token issuers and related crypto service providers from granting interest. Its definition covers benefits linked to holding duration, including certain compensation and discounts. Income earned on reserve assets and a return promised to token holders are distinct questions under those rules.
Authorization is separate too. The Commission’s guidance published by ESMA says issuers of stablecoins offered publicly or admitted to trading in the EU must meet MiCA authorization requirements, subject to applicable transitional provisions. Rewriting one reserve condition would not itself authorize an issuer or approve an exchange listing.
The guidance dates the application of MiCA’s stablecoin provisions to June 30, 2024. It also explains that public offers and admission to trading by parties other than the issuer remain subject to the framework. Distribution through an intermediary is not, by itself, a way around issuer requirements.
That distinction remains relevant after Revolut’s reported USDT restrictions. A proposal concerning reserve composition does not reverse a provider’s product decisions or establish that any particular token has completed the required authorization process.
Broader crypto sentiment remained positive: Alternative.me’s index measured 71, or Greed, for September 23. Sentiment provides market context, not a measure of legislative support.
Fear & Greed Index
September 23, 2026The Commission’s consultation closes September 30 at 23:59 CEST. Responses will inform its review report, potentially accompanied by legislation. Whether it adopts these recommendations, the eventual thresholds and any implementation timetable remain unresolved; the consultation deadline itself changes no reserve obligation.
Stay up to date
Get the latest crypto insights delivered to your inbox
Primary sources and further reading
| Source | Title |
|---|---|
| | ESCB: September 2026 response to the MiCA review |
| | European Commission: MiCA review consultation and deadline |
| | EBA: Draft reserve liquidity technical standards |
| | ESMA: MiCA Article 50 interest prohibition |
| | European Commission via ESMA: Stablecoin issuer authorization requirements |
| | Circle: March 2023 SVB reserve exposure and recovery |
| | CoinGecko: Bitcoin market data |
| | Alternative.me: Crypto Fear and Greed Index |
Fact-checked by: Daily Crypto Briefs Fact-Check Desk
Related Articles
Frequently Asked Questions
Has the ECB removed MiCA's stablecoin deposit rule?
No. The September 22 publication is a consultation response proposing changes, not an amendment to EU law.
What could replace the 60% bank-deposit requirement?
Minimum shares of reserves available within one and five working days. The EBA's draft benchmarks are 40% and 60% for significant tokens, with the first share included in the second.
Does the proposal approve USDT trading in the EU?
No. Changing reserve requirements would not itself satisfy separate MiCA issuer authorization and public-offering requirements.
When does the MiCA review consultation close?
The European Commission lists September 30, 2026, at 23:59 CEST as the extended deadline. That is a response deadline, not a date when rules change.