When a major stablecoin issuer answers a regulator’s consultation, the document is advocacy, not law. That distinction matters for Europe’s Markets in Crypto-Assets framework—better known as MiCA—the EU rulebook for crypto-assets, including certain stablecoins.
On 1 October 2026, Circle published its response to the European Commission’s targeted consultation on the MiCA review. Circle frames the submission around its experience as a MiCA-authorised issuer of USDC and EURC. [1]
A stablecoin here means a crypto-token designed to track a fiat currency. Under MiCA, many such tokens sit in the e-money token (EMT) category when they reference a single official currency.
What Circle says it wants preserved
Circle argues for keeping multi-issuance: a structure in which a globally circulating stablecoin is co-issued by a MiCA-authorised EU entity alongside a foreign-regulated counterpart. In Circle’s telling, that is currently how global liquidity can sit inside MiCA’s perimeter. [1]
As a longer-term complement, Circle proposes an equivalence and recognition path for foreign-regulated stablecoins, modelled on existing EU equivalence frameworks and, it says, the U.S. GENIUS Act approach to foreign payment stablecoins. [1]
What Circle wants changed on reserves
Circle says MiCA’s mandatory commercial-bank deposit minima—30% of reserve assets, rising to 60% for “significant” EMTs—increase banking-sector credit and counterparty risk. It backs replacing that rigid floor with liquidity-focused reserve rules, citing concurrence with the ECB on reconsidering the minimum. [1]
It also asks the Commission to remove two EBA Level 2 concentration caps that, in Circle’s view, hinder USD EMT issuers from holding primarily sovereign high-quality liquid assets and force larger issuers to spread deposits across many bank counterparties. [1]
Figures Circle cites about the market
Circle positions itself as the largest MiCA-authorised EMT issuer for both USDC and EURC. It cites roughly 30 authorised EMTs under MiCA, and says that of the top 25 stablecoins globally by market capitalisation, only three—USDC, USDG and EURC—are currently MiCA-regulated. Those rankings and “largest” claims are Circle’s company statements, not independent league tables verified here. [1]
Why the consultation response matters
This is formal input from a large EMT issuer into the first MiCA review cycle. The themes—how EU rules meet global liquidity, and how reserve composition is constrained—are the live policy questions, even though none of Circle’s asks is a Commission decision.
What this does not prove
- That the Commission will preserve multi-issuance, adopt equivalence, or rewrite deposit minima. [1]
- That Circle’s market-cap and “largest issuer” claims have been independently audited in this piece. [1]
- That MiCA-regulated status alone determines which stablecoins dominate EU usage.
The Bottom Line
Circle’s 1 October post is a company consultation response: keep multi-issuance, build longer-term recognition for foreign-regulated coins, and soften rigid bank-deposit and concentration rules. Treat every ranking and priority as Circle-reported advocacy—useful colour on what a major issuer wants from MiCA’s next phase, not as new EU law.
Sources
- Circle blog, response to the European Commission’s MiCA review consultation — 1 October 2026 — https://www.circle.com/blog/circles-response-to-the-european-commissions-mica-review-consultation
