ECB and EU central banks call on regulators to scrap the 60 per cent bank deposit rule for major stablecoin issuers under MiCA review
The European System of Central Banks (ESCB), comprising the European Central Bank (ECB) and the national central banks of all 27 EU member states, published a response on 22 September 2026 to a consultation on the Markets in Crypto-Assets (MiCA) regulation, arguing that a key reserve requirement for stablecoin issuers should be reformed. Under the current MiCA framework, which came into force in 2024, major stablecoin issuers are required to hold at least 60 per cent of their reserve assets as bank deposits. The ESCB response argues that this requirement exposes banks to destabilising risks, because stablecoin-related deposits are less sticky (meaning more likely to be withdrawn rapidly) than conventional deposits, and because changes in the stablecoin market could trigger sudden outflows from the banks holding those reserves. Instead of the 60 per cent bank deposit floor, the ESCB recommends replacing it with a requirement for a minimum proportion of reserve assets to be held in instruments that mature within one to five working days, a structure designed to prioritise liquidity over bank exposure. The ESCB also warned that European regulators face 'material challenges' in enforcing MiCA, because non-compliant crypto companies continue to access EU customers, creating ongoing investor protection risks. The response underscores the tension between the ambition of MiCA as a comprehensive crypto regulatory framework and the practical challenges of enforcement at the edges of the EU single market.
Why this matters
The ESCB's proposed change to the reserve composition rule is technically specific but commercially significant: if adopted, it would substantially reduce the volume of stablecoin-linked deposits held by commercial banks, affecting their funding profiles and potentially their capacity to offer stablecoin custody services. The central banks' concern about deposit stickiness reflects a lesson drawn from the 2023 US banking turmoil, where concentrated digital-asset deposits proved highly volatile. The enforcement gap highlighted by the ESCB is equally important: MiCA's reach is only as strong as the ability to stop non-compliant offshore issuers from serving EU retail customers, and the ESCB is signalling that this remains an unresolved structural weakness.
On the Ground
Financial regulation lawyers advising stablecoin issuers, crypto exchanges, and their banking partners will need to track whether the MiCA review adopts the ESCB's proposed liquidity-based reserve model, since a change would require a fundamental redesign of reserve management arrangements. Banking lawyers advising institutions that hold stablecoin issuer deposits will want to assess the business case for those relationships if the 60 per cent floor is removed. A trainee on a MiCA compliance matter would assist with drafting a regulatory notification summarising the ESCB's proposed changes, preparing a compliance gap analysis comparing current reserve arrangements against the proposed new requirements, and coordinating with local counsel in EU member states where the issuer is authorised.
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“Why does the ECB oppose the current MiCA requirement for stablecoin issuers to hold 60 per cent of reserves as bank deposits, and what does that tell us about the relationship between crypto regulation and financial stability?”
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