Circle Wants MiCA to Trade Bank-Deposit Quotas for a Liquidity Test

Circle Wants MiCA to Trade Bank-Deposit Quotas for a Liquidity Test


European Union flags outside the European Commission building in Brussels image By Isaac • October 2, 2026 11:22 am •

Circle is asking European regulators to rethink one of MiCA’s most concrete stablecoin rules: the share of reserves that issuers must keep as commercial bank deposits.

The USDC and EURC issuer says the requirement is meant to promote safety, but can concentrate the very bank and counterparty risks that a reserve framework should reduce. Its alternative is a broader liquidity test that focuses on whether assets can meet redemptions under stress.

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In its formal response to the European Commission’s MiCA review, Circle said the regulation currently requires e-money token issuers to place at least 30% of reserves in commercial bank deposits. The floor rises to 60% for tokens classified as significant.

Circle argues that a rigid

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