Circle urges the EU to replace MiCA's bank-deposit minimum for stablecoin reserves

Three of 25 is 12 percent ^[1]. According to Circle's submission, the three are USDC, USDG and EURC ^[2]. Roughly 30 e-money tokens are authorized in total ^[3], so about 27 licensed tokens sit outside the global top 25 ^[2]. The count comes from Circle's October 1 response to the Commission's consultation ^[1]. Circle issues two of the three ^[3] and says it has operated under MiCA for two years ^[18]. I'd treat the count as a description of where licensed supply sits today. The submission, as cryptotimes.io reports it, organizes its requests around bringing larger global tokens inside the framework ^[23]. It does not connect the absence of any of the other 22 ^[4] to a specific rule.

On the deposit floor, Circle says it agrees with the European Central Bank that the minimum should be reconsidered and replaced with a less rigid minimum asset liquidity requirement ^[8]. That ECB position is known here only secondhand, through Circle's filing. Circle's objection to the per-bank cap is a different one. It says the cap would force larger issuers to keep relationships with numerous separate banks, adding operational complexity and risk ^[11]. The two rules add up. The floor sets how much of a reserve must sit in banks ^[6], and the cap limits how much any one bank can take, so the number of banks rises with the size of the issuer ^[11].

Circle is defending multi-issuance. Most stablecoins in global circulation are issued by entities regulated outside the EU ^[4]. Under multi-issuance, a MiCA-authorized EU entity co-issues a global token alongside its foreign-regulated counterpart ^[5]. Circle says this is currently the only structure that lets that global liquidity operate inside MiCA's regulatory perimeter ^[5]. The filing cites the Commission's own 2020 impact assessment for MiCA, which noted the risk that prohibiting foreign stablecoins could push users to obtain them from offshore parties outside the EU ^[13]. For the longer term, Circle's equivalence route would have two levels: a Commission-level determination that a foreign regime is equivalent, then entity recognition at the European Banking Authority ^[16].

A separate case concerns the same perimeter. Binance did not obtain a MiCA license and was expected to wind down its EU business from July 1 ^[19]. The European Securities and Markets Authority and regulators in France, Germany and Greece have requested information on its reliance on the reverse-solicitation exemption ^[20]. Tests by the Geneva-based publication Sandmark on August 19, 2026, found that new accounts could still be opened, verified and funded from several EU countries after the deadline ^[21].