Circle's MiCA consultation response is a bid to shape how the EU treats stablecoins issued jointly by EU-licensed and foreign-regulated entities, rather than a simple compliance filing. The core tension is scope: roughly 30 e-money tokens are authorized in Europe, yet only USDC, USDG and EURC among the top 25 global stablecoins fall under MiCA, so Circle argues the framework currently regulates the smaller market and leaves the largest tokens outside. Its proposed equivalence and recognition regime, modeled on EMIR, CSDR and MiFIR, would shift primary supervision to home-jurisdiction regulators while keeping equivalence decisions and EBA recognition at EU level, a structure that could ease cross-border issuance if adopted. Watch whether the European Commission and EBA signal openness to equivalence for foreign-regulated stablecoins, whether the ECB revisits the 30% commercial bank deposit reserve requirement, and whether the two EBA concentration rules Circle wants removed are amended in the technical standards.
PANews reported on October 2 that Circle disclosed it has submitted a response to the European Commission's targeted consultation on MiCA. Circle said MiCA has already given Europe a first-mover advantage, with around 30 e-money tokens currently authorized, but only 3 of the world's top 25 stablecoins by market cap are regulated under MiCA — namely USDC, USDG and EURC. The gap lies in MiCA's regulatory scope failing to cover the largest global tokens.
Circle recommends retaining the multi-issuer structure, under which globally circulating stablecoins are issued jointly by MiCA-authorized EU entities and foreign regulated entities, and recommends establishing an equivalence and recognition regime for foreign-regulated stablecoins similar to EMIR, CSDR and MiFIR, with regulators in the issuer's home jurisdiction taking primary supervisory responsibility, while equivalence determinations and EBA entity recognition are carried out at the EU level. On reserve requirements, Circle believes MiCA's requirement that issuers deposit at least 30% of reserve assets in commercial bank deposits would increase bank credit and counterparty risk, supports the European Central Bank reconsidering this requirement, and recommends removing two concentration rules from the EBA technical standards.
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