The Digital Euro Association responded to the European Commission's targeted consultation on the review of the Markets in Crypto-Assets Regulation (MiCA) which closed on 30 September 2026. We focused on stablecoins, where our research and our community's expertise are strongest. Our answers combine DEA's published positions and working group research, with input from members and contributors across our community, and the response marks clearly which is which.
One idea runs through our proposals. A stablecoin is only as safe as the path back to holders' funds. MiCA should be judged on whether that path still works in a stress event, including when the issuer, the reserves and the holder are in different countries.
Redemption that works for every holder
Every eligible holder should be able to redeem their tokens, subject to identity, anti-money-laundering and sanctions checks. Where one token is issued inside and outside the EU, we do not support EU residence as a general basis for restricting redemption, or a route that runs only through crypto-asset service providers and so excludes people who hold tokens in their own wallets. Limiting who can redeem also adds nothing to the reserves; it only shifts losses from one group of holders to another.
Holder claims and reserve protection must stay clear and enforceable if an issuer fails. A proportionate resolution arrangement for e-money institutions that issue stablecoins deserves assessment. It should cover recovery of assets, continuity of essential functions and orderly wind-down, without simply copying bank resolution. Recovery and redemption plans should be tested in coordinated simulations of bank or custodian failure and cross-border disruption.
MiCA requires e-money institutions that issue stablecoins to hold 30 to 60 percent of their reserves in bank deposits. That was a reasonable initial safeguard. It is not a complete or permanent measure of redemption safety. Over time, and based on evidence, we asked the Commission to move toward liquidity-based requirements, which test whether reserves can meet redemptions under stress rather than where they are held. These would allow more short-term government securities and other liquid instruments, under clear maturity, quality and concentration standards. This would also reduce the stablecoin sector’s dependence on bank deposits over time. As our previous research indicates, this would reduce a two-way contagion risk. The failure of a bank holding part of a stablecoin's reserves can undermine confidence in the stablecoin and trigger large-scale redemptions. Meeting those redemptions can, in turn, force the issuer to withdraw deposits from otherwise sound banks. Any change should rest on stress evidence, not on a new fixed percentage.
MiCA should stay open to multi-issuance, where EU and non-EU entities issue the same token. This follows the joint industry letter we co-signed in November 2025 and the European Parliament's call for legal certainty in July 2026. Openness needs conditions: clear issuer liabilities, high-quality liquid asset reserves, a redemption route that still works after the token has changed hands, and group reserve support that remains usable under foreign insolvency or transfer restrictions.
We also support an outcomes-based equivalence route for qualifying global issuers. It should have a clear legal basis, ongoing monitoring and the power to suspend recognition. Recognition must never waive redemption, reserve or supervisory outcomes for EU holders.
No issuer of asset-referenced tokens (ARTs) has yet been authorised under MiCA. The Commission should test whether the category meets a real market need before adding new liquidity or stress-test rules to it, while keeping today's safeguards. For significant stablecoins, we support keeping the current thresholds under regular review and collecting better data on holder concentration and redemptions before adding new triggers.
MiCA bans issuers and crypto-asset service providers from paying holders interest, or any other benefit linked to how long they hold the token. Issuers keep the interest their reserves earn. As our previous research recommends, we call for a dedicated, evidence-based study of interest-bearing euro stablecoins before any change to that ban. It should look at bank funding, monetary transmission, redemption incentives, holder protection, and the line between payment and investment products.
We take the same approach to the rule that treats every stablecoin denominated in an EU currency as offered in the EU. The rule gives a clear link to EU law, but it adds cost where circulation in the EU is small. We asked for data before any change.
Our answers build on DEA's Position Statement, our working group research, including The Role of Stablecoins in Financial Sovereignty (2025), and joint industry letters we helped draft, including November 2025’s "Publication of MiCA Q&A Essential to Safeguard Europe’s Competitiveness.” We also drew on input from contributors across our community.
We distinguished these sources clearly in the response text. Throughout the response, we indicate where a point rests on DEA's published position and where it comes from contributor input, and we reference the documents behind each answer. Where contributors disagreed, for example on how quickly the bank-deposit share should change, we say so. Individual contributors are not named in the submitted response.
The Commission is due to report on MiCA by June 2027. This month we begin the review of our Position Statement with members, and the response will now serve as an important input into that process. Our full response will be available on the Commission's consultation page once it is published.
Thank you to everyone who contributed to this response. Academics, legal researchers, issuers and practitioners gave their time and expertise over the summer. We are grateful, and we trust you will stay involved as the ecosystem evolves.