The European System of Central Banks, made up of the European Central Bank and the 27 national central banks of the EU, filed a 57-page response on September 22, 2026, to the European Commission's targeted consultation on reviewing the Markets in Crypto-Assets Regulation (MiCA). The submission asks Brussels to scrap the regulation's fixed bank-deposit floor for stablecoin reserves and to extend the existing ban on stablecoin interest to cover indirect yield generated through lending, staking or bundled services.
What MiCA requires today
MiCA requires issuers of e-money tokens, the category that covers most euro and dollar stablecoins sold in the EU, to hold a minimum share of their reserves as deposits at credit institutions: at least 30% for an ordinary token, and at least 60% for a token designated "significant," a status tied to holder counts, market capitalization and transaction volumes. As of August 8, 2026, 22 stablecoin issuers held EU authorization under MiCA.
A liquidity test instead of a deposit floor
The ESCB wants that fixed percentage replaced with a liquidity-based requirement pegged to how fast reserves can be converted to cash. It proposes using, as a starting point subject to further calibration, the thresholds already drafted by the European Banking Authority in a draft technical standard that has not yet been approved: 40% of a significant stablecoin's reserves in assets maturing within one business day and 60% within five business days; 20% and 30% for other e-money tokens.
| Token status | MiCA today (bank deposits) | EBA draft adopted by ESCB (liquid within 1 / 5 business days) |
|---|---|---|
| Significant stablecoin | 60% minimum | 40% within 1 day, 60% within 5 days |
| Other e-money token | 30% minimum | 20% within 1 day, 30% within 5 days |
The central banks' stated concern is contagion risk running the other way from what MiCA was designed to prevent. Concentrating stablecoin reserves as deposits at a small number of banks ties those banks' funding to a source that can be withdrawn all at once if token holders rush to redeem, straining bank liquidity at the moment it is most needed. A liquidity-based rule, the ESCB argues, gives issuers cash on a matching schedule without forcing that concentration.
Closing the yield loophole
MiCA already bans stablecoin issuers from paying interest directly to holders, on the premise that e-money tokens should function as a payment instrument rather than a savings product. The ESCB's response argues that ban is easy to route around: a token can be "transformed into yield-bearing arrangements through lending, staking or layered structures" offered by exchanges, DeFi protocols or other intermediaries, none of which count as the issuer paying interest under the current wording.
Timeline
Nothing changes for stablecoin issuers immediately: MiCA's current 30%/60% deposit floor and its ban on direct interest stay in force while the Commission weighs the consultation responses alongside submissions from other participants. Any change would require the Commission to bring a legislative proposal to amend MiCA itself, something its review report, due around mid-2027, may or may not recommend.