Invest2 publishers2 min readPublished
The ECB asks Brussels to delete MiCA's 60% bank-deposit floor for stablecoin reserves
The ECB's September 22 submission to the Commission's MiCA consultation asks for the deposit percentages to go, with reserve assets instead having to mature within one to five working days. Significant token issuers currently park 60% in banks.
The Investor · Invest desk
What happened
- The ECB and the European System of Central Banks filed their formal response to the European Commission's MiCA consultation on September 22.
- Their central recommendation is to eliminate the percentage-based bank-deposit mandate for stablecoin reserves and build the rule around liquidity instead of thresholds.
- MiCA currently makes e-money token and asset-referenced token issuers hold at least 30% of reserves in bank deposits, rising to 60% for tokens classified as significant.
- The ECB's stated reason is that mandated deposits leave banks holding volatile balances that could vanish from a balance sheet overnight in a redemption wave.
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Why it matters
- capability Deletion would take a significant issuer's freely deployable reserves from 40% of the book to all of it, a pool 2.5 times larger to run against short-dated government paper.
- constraint The yield relief scales with size: at a one-point spread on the 60% share, a 2 billion euro reserve book picks up about 12 million euros a year, so the money in this argument sits with the biggest issuers.
- decision Anyone structuring euro stablecoin reserves for next year is now planning against a percentage the central bank has asked the Commission to remove, and the Commission owns that choice.
- exposure Redesigning reserves does not touch the gap the ESCB reported, since platforms outside European borders can serve EU users whatever the deposit floor says.
A token designated significant keeps 60% of its reserves in bank deposits [3], and deposits generally pay less than short-duration government securities or other high-quality liquid assets [8]. Crypto Briefing put that gap at hundreds of millions in annual revenue for an issuer holding billions in reserves [10]. Assume a one-percentage-point spread on the mandated 60% share, and 200 million euros a year requires roughly 33 billion euros of reserves [15]. On a 2 billion euro book, the same spread is worth about 12 million [16].
Industry groups had made a different argument. Bruegel and Blockchain for Europe said forcing reserves into bank deposits limits operational flexibility and ties a token's stability to individual banking relationships [7]. Significance, as MiCA applies it, doubles the floor from 30% to 60% [13], so the largest euro tokens are the ones most tied to a single counterparty and the ones with the most to gain from deletion: their freely deployable share goes from 40% of reserves to all of it [14].
Whether the swap raises issuer income is open. The maturity test as described applies to reserve assets generally, and paper maturing within one to five working days is not the three-month bill that a deposit-versus-bills comparison implies [5]. A five-day ceiling across the whole book could bind harder than full discretion over the curve on 40% of it. The ECB's response treated the question in macro-financial terms and did not name any issuer or token [12].
The 30% floor applies to non-significant tokens [3]. At 500 million euros of reserves and the same one-point assumption, deleting it is worth about 1.5 million euros a year [18]. The smaller end of the market has argued this as an operational burden.
MiCA's stablecoin provisions became fully applicable during 2024 and 2025, making Europe the first major jurisdiction to impose a comprehensive framework on crypto assets [11]. The US GENIUS Act imposes no comparable deposit percentage [9], and if the Commission takes the advice, MiCA loses the reserve feature that separated the two.
What to watch
- Whether the Commission's MiCA review text keeps a percentage floor for significant tokens, drops it only for non-significant ones, or deletes both.
- Whether the one-to-five-working-day maturity test would apply to the whole reserve book or only to the share that replaced the deposits.
- Bank disclosures sizing stablecoin-issuer deposit balances would show how much money leaves EU banks if the floor goes.