Why Does the ECB Want to Change MiCA's Stablecoin Deposit Rule?

In brief: The European Central Bank and the national central banks that form the European System of Central Banks want Brussels to replace MiCA's minimum bank-deposit requirement for stablecoin reserves with liquidity thresholds. In its response to the European Commission's targeted review of MiCA, published on 22 September 2026, the ESCB argues that forcing issuers to park large shares of their reserves in bank deposits concentrates risk in the banking system rather than removing it, and that a redemption rush could drain those deposits at the worst possible moment.

The supervisors that write the rules for the euro now want to rewrite one of them. According to Cointelegraph, the ECB and EU central banks are asking the European Commission to scrap the fixed bank-deposit floors that MiCA imposes on stablecoin reserves and put liquidity requirements in their place. The concern is not that issuers hold too little at banks. It is that they may hold too much, and that a sudden wave of redemptions could pull those deposits out of lenders precisely when funding is scarce.

What does MiCA currently require issuers to hold at banks?

MiCA, formally Regulation (EU) 2023/1114, came into force on 31 May 2023, with its stablecoin provisions applying from 30 June 2024. The regulation splits payment-style stablecoins into two categories: e-money tokens, which reference a single official currency such as the euro or the dollar, and asset-referenced tokens, which track a basket or other values.

The deposit rules sit inside the reserve regime. Under Article 54, funds received in exchange for e-money tokens must be safeguarded, and at least 30 percent of those funds must always be deposited in separate accounts at credit institutions, as Crypto Times sets out in its reading of the text. For tokens the European Banking Authority classifies as significant, the floor is higher still: the additional rules drawn from the asset-referenced chapter can require a deposit floor no lower than 60 percent of the amount referenced in each official currency. The EBA's technical standards layer concentration limits on top, capping any single credit institution at 25 percent of the cash reserve for ordinary tokens and 10 percent for significant ones.

Put plainly, the design assumes that the safest home for a large slice of stablecoin reserves is a bank. The central banks now dispute that assumption.

Why do the ECB and EU central banks want the rule changed?

The central banks want mandatory deposit thresholds replaced with liquidity requirements because the current design pushes stablecoin risk into the banking system rather than away from it. Their argument, filed in the ESCB response to the Commission's MiCA review, runs on two fronts.

The first is concentration. Requiring issuers to place a fixed, large portion of reserves in bank deposits makes lenders reliant on a funding source that behaves nothing like ordinary retail money. Stablecoin reserves can move fast, in size, and in one direction. The second is the run problem. If holders lose confidence and redeem at once, the issuer has to pull its deposits to meet them, withdrawing wholesale funding from banks exactly when the system is under stress. In the ESCB's framing, a rule meant to protect stability could instead transmit it.

The proposal fits a longer line of ECB commentary. In its Financial Stability Review coverage, the bank warned that significant growth in stablecoins could cause retail deposit outflows, diminishing an important source of bank funding and leaving lenders with more volatile balance sheets. The primary vulnerability, the ECB has said repeatedly, is that investors lose confidence they can redeem at par. ECB board member Piero Cipollone has made the deposit-erosion point directly, arguing that stablecoin adoption weakens the banking deposit base, per Cointelegraph's reporting of his remarks.

How large is the risk the ECB is worried about?

In the euro area, the exposure is still modest, but the trajectory is what alarms supervisors. Global stablecoin capitalisation has roughly doubled since 2023 to around 300 billion dollars, with dollar-denominated instruments accounting for close to 99 percent of the market, according to Ledger Insights. Euro-denominated issuance sits near 395 million euros against that backdrop, a rounding error by comparison.

Scale matters because the largest issuers are no longer peripheral. The ECB has noted that major stablecoin issuers now hold reserve portfolios comparable to the world's biggest money market funds and rank among the top recent buyers of US Treasury bills. A disorderly redemption at that size would not stay contained to crypto markets; it would ripple into short-term funding and sovereign debt. The European Systemic Risk Board reinforced the point in its October 2025 recommendation, flagging systemic risk from stablecoins and, in particular, from multi-issuance schemes where the same token is issued by both EU and non-EU entities.

How would liquidity thresholds differ from deposit floors?

The distinction is between a static rule and a dynamic one. A deposit floor asks where reserves sit. A liquidity threshold asks how fast they can be turned into cash to honour redemptions, and whether meeting that demand forces destabilising withdrawals from lenders. The central banks argue the second question is the one that actually maps to the risk.

What happens next in the MiCA review?

The request lands inside a live process. The European Commission opened a targeted consultation on the MiCA review earlier in 2026, with the response window extended to 30 September 2026, as Norton Rose Fulbright has documented. The ESCB submission is one input among many, and any change to Article 54 or the significant-token regime would require legislative amendment rather than a supervisory notice. Nothing shifts overnight.

What institutions can take from this is a signal about direction. Reserve composition, redemption mechanics, and the interplay between issuer liquidity and bank funding are moving to the centre of the European debate, and the fixed-percentage deposit rule that has anchored compliance since June 2024 is no longer treated as settled. For issuers building programmable, redeemable instruments against real reserves, the premium is increasingly on demonstrable liquidity and transparent, auditable backing rather than on a single deposit ratio, which is precisely the ground Issuant is built to serve.