​The EBA classifies USDC as the first significant e-money token in the European Union

Key dates

2026-10-14

The EBA announced that USDC issued by Circle Internet Financial Europe SAS had been classified as a significant EMT under MiCA.

2026-11-12 Deadline

Dual supervision of USDC begins: the EBA assumes direct responsibility for own funds, reserve of assets, liquidity requirements, and recovery and redemption plans, while the ACPR retains specified governance and organisational responsibilities.

Suggested considerations

• Circle and its regulatory counsel should map existing own-funds, reserve-of-assets, liquidity, recovery, and redemption controls to the EBA’s supervisory expectations and establish clear evidence and reporting channels before 2026-11-12.
• Circle should confirm the allocation of responsibilities between the EBA and ACPR, including supervisory contacts, escalation procedures, information requests, and documentation ownership for prudential and organisational matters.
• Crypto-asset service providers should reassess their USDC due diligence, product governance, liquidity, redemption, custody, safeguarding, and operational-risk controls in light of the significant-EMT designation.
• Firms using USDC should identify exposures in client assets, settlement, treasury, collateral, and payment flows and assess whether updated counterparty, liquidity, concentration, and business-continuity assessments are appropriate.
• Compliance teams should monitor EBA and ACPR communications, supervisory-college activity, and any subsequent guidance or requests concerning significant EMT reporting and recovery or redemption planning.
• Firms operating across the EU and United States should review information-sharing, incident-notification, and cross-border supervisory arrangements, noting the EBA’s memorandum of understanding with the New York State Department of Financial Services.

What changed

USDC will be subject to the MiCA framework for significant EMTs from 2026-11-12. The EBA will assume direct supervisory responsibility for own-funds requirements, the reserve of assets, liquidity requirements, and recovery and redemption plans; the ACPR will continue supervising governance, qualifying holdings, fit and proper assessments, outsourcing, and conflicts of interest. Under MiCA Articles 56 and 43(1), an EMT is classified as significant where at least three significance criteria are met during the applicable reporting periods. The criteria include more than 10 million holders, issued value or market capitalisation or reserve value exceeding EUR 5 billion, more than 2.5 million transactions or transaction value exceeding EUR 500 million on an average daily basis, gatekeeper status

Who is affected

• Circle Internet Financial Europe SAS as the EU issuer of USDC
• EU-authorised crypto-asset service providers offering custody, trading, exchange, transfer, or other services involving USDC
• EU credit institutions and investment firms using USDC in payments, treasury, settlement, or investment activities
• Non-EU entities and supervisory authorities involved in USDC’s cross-border issuance, distribution, or reserve arrangements

Related regulations

• Regulation (EU) 2023/1114 on Markets in Crypto-assets (MiCA), Articles 43, 56, 117, 119 and 128
• Commission Delegated Regulation (EU) 2024/1506 specifying criteria for classifying asset-referenced tokens and e-money tokens as significant
• EBA Decision EBA/DC/558 on the indicators used for significance assessments
• Regulation (EU) 2022/1925 on digital markets, insofar as gatekeeper status is one MiCA significance criterion