The European Banking Authority published its response to the European Commission's targeted consultation on the MiCA review on September 24, 2026. Its answer on the core question is that existing MiCA requirements for issuers of asset-referenced tokens and e-money tokens are broadly appropriate. Its recommendations cover five areas: third-country multi-issuer schemes, the reserve requirements, MiCA's scope and definitions, crypto-asset lending, and the reporting framework.
39 e-money tokens, no asset-referenced token
The state of the market frames the whole response. As of September 1, 2026, the reference date the EBA used, 39 e-money tokens had been issued under MiCA across the EU, 36 of them by e-money institutions, and no asset-referenced token had been authorized under Title III. The EBA draws an explicit conclusion: too little experience has been acquired to consider changes to the requirements for that second category.
Third-country multi-issuer schemes
On schemes where the same token is issued by entities inside and outside the EU, the EBA recommends that the Commission consider regulatory changes to strengthen the framework. The purpose it assigns them is to mitigate what it calls the significant to very significant risks these schemes pose. In its detailed response it holds that MiCA's existing tools mitigate those risks only in part. It cites the liquidity stress testing under Article 45 and the recovery and redemption plans under Article 46, and recommends subjecting the schemes to a dedicated regulatory and supervisory regime.
On reserves, the EBA asks for a review of the requirements that apply to issuers, and names the minimum amount of reserves that must be held as deposits. It wants that reviewed while preserving effective risk management, which is a narrower position than removing the floor.
Crypto-asset lending, outside MiCA's current scope
The EBA encourages the Commission to consider regulating crypto-asset lending, citing the risks it poses to consumers, and is specific about the case that worries it: crypto-asset service providers that facilitate customer access to decentralized lending protocols. A consumer who deposits through a regulated firm and ends up exposed to a protocol has no counterparty in the regulated sense.
It also asks for clearer scope and definitions, on a practical ground rather than a doctrinal one. The classification of crypto-assets under MiCA, it says, is a challenge for industry and supervisors alike, and it results in avoidable costs and delays for firms rolling out products. That impedes innovation and undermines the competitiveness of the EU market.
A consultation response, not a rule
What the EBA published is its answer to a Commission questionnaire. It carries weight because the same authority writes the technical standards and supervises the largest issuers, but it creates no obligation and sets no date. The Commission decides what enters a legislative proposal, and the Parliament and the Council decide what survives it.
The reporting request is the one most likely to reach firms first, because it can be handled through technical standards rather than a change to the regulation. For an issuer that already files under MiCA, the reporting templates are therefore likely to move before the substance does.
The timetable from here
Nothing changes today. The Commission's consultation closes on September 30, 2026, and any legislative proposal follows from there. For an issuer or a service provider, the list of what supervisors consider unfinished shows where the next round of requirements will land: third-country structures, crypto-asset lending and the reporting framework.