Circle is calling on the European Commission to change the European Union’s stablecoin reserve requirements, arguing that mandatory bank deposits can expose issuers to banking-sector risks. The proposal was submitted during the Commission’s consultation on the review of the Markets in Crypto-Assets Regulation, known as MiCA.
Circle’s proposed reserve changes
According to Cointelegraph, Circle said the current rules should be replaced with a more flexible minimum liquidity requirement. The company issues USDC and EURC and argued that requiring stablecoin issuers to keep specified amounts in commercial bank deposits creates credit and counterparty exposure to those banks.
Under MiCA, issuers of e-money tokens must currently hold at least 30% of their reserves in commercial bank deposits. The minimum rises to 60% for issuers classified as significant, according to Circle.
Circle also asked the Commission to remove two concentration limits. One caps exposure to a single sovereign at 35%, while another limits deposits held with each counterparty to an amount equivalent to 1.5% of that bank’s total assets.
The company’s concerns draw on its experience in March 2023. USDC temporarily moved away from its one-dollar peg after Circle disclosed that $3.3 billion of its reserves were held at Silicon Valley Bank. The funds were later made available after US authorities protected the bank’s depositors.
Cross-border issuance at the centre of debate
Circle also wants the EU to retain “multi-issuance.” This structure allows an EU-authorized entity and a foreign-regulated counterpart to co-issue a stablecoin.
The issuer argued that restricting multi-issuance could drive users toward offshore providers that do not operate under MiCA’s protections. The consultation closed on Wednesday, and responses will contribute to the European Commission’s assessment of how MiCA is working, whether it remains fit for purpose as crypto markets evolve, and which activities may need to be brought within its scope.
Circle said its position on reserve requirements is aligned with the European Central Bank’s support for reconsidering mandatory deposit minimums in favour of a more flexible liquidity approach.
Other groups seek broader MiCA changes
Circle was not the only organisation to submit proposals. The Hyperliquid Policy Center urged the Commission to regulate crypto perpetual futures through the EU’s existing securities and derivatives framework, MiFID II. It also called for rules tailored to the structure of perpetual futures markets and for public blockchain records to be recognised for transparency and recordkeeping purposes.
The Global Blockchain Business Council proposed clearer token classifications, proportionate safeguards for stablecoins and less overlap between MiCA and payment-services rules. On cross-border issuance, it requested clear redemption responsibilities, enforceable reserve rebalancing and an accountable EU supervisory framework.
Moneyiar market picture
Moneyiar data at 09:14 on October 3, 2026, showed mixed performance among the listed assets:
- Cronos (CRO): $0.0662593983, down 3.9% over 24 hours and up 0.97% over seven days.
- Stable (STABLE): $0.0265788512, down 6.11% over 24 hours and up 1.34% over seven days.
- Comedian (BAN): $0.0627530322, down 4.85% over 24 hours and down 9.12% over seven days.
- ONEchain (ONE): $0.1408084884, up 1.77% over 24 hours and down 6.05% over seven days.
These market figures cover separate crypto assets and do not indicate the outcome of the EU’s MiCA review.
