From 12 November, the European Banking Authority will supervise the reserve behind USDC in the European Union, a job France’s ACPR has done until now. The EBA said on 14 October that it had classified USDC, issued in the EU by Circle Internet Financial Europe SAS, as a significant e-money token under MiCA. USDC is the first of the 45 e-money tokens notified in the EU to get that label, which makes it the first stablecoin whose backing an EU body, not a national one, will check directly.
The decision is four days old. The date that matters is the handover. On 12 November the EBA takes charge of four files for USDC: own funds, the reserve of assets, liquidity requirements, and the recovery and redemption plans. The ACPR, which sits within the Banque de France, keeps the rest of the supervision: governance, qualifying holdings, fit and proper assessments, outsourcing and conflicts of interest. The two authorities say they will cooperate so the transfer goes smoothly.
For anyone asking whether USDC is still MiCA compliant, the answer does not change. The token in a European wallet or on a European exchange is the same, and the right MiCA’s Article 49 gives every holder, to redeem the token at any time and at par value from the EU issuer, with no fee outside a recovery plan, stays where it was. What changes is the rulebook Circle’s French entity has to meet, and who checks it.
The USDC MiCA decision: what the EBA said and what it left out
In the words of the EBA’s release, “USDC is the first one to be classified as being significant”. The authority cites MiCA Articles 43 and 56 for the classification, the indicators set out in Commission Delegated Regulation (EU) 2024/1506, and its own procedure, Decision EBA/DC/558, published on 22 October 2024. That procedure has the EBA send a draft decision to the issuer, its home authority and the European Central Bank, which then have 20 working days to send written observations.
The release is short on detail. Beyond the count of 45 notified tokens it gives no figures, it does not say which of MiCA’s criteria USDC met, it carries no quotes and it does not mention EURC, Circle’s euro token. It does note that USDC is also issued in the United States by Circle Internet Financial, LLC, and that the EBA has a memorandum of understanding with the New York State Department of Financial Services (NYDFS) on cooperation and information exchange for cross-border stablecoin activity. Reports differ on when that memorandum was signed, so we do not date it.
The road here was long. MiCA was published in the EU’s Official Journal on 9 June 2023, and its stablecoin titles started to apply on 30 June 2024. The next day, 1 July 2024, Circle announced that the ACPR had granted its French entity an electronic money institution licence, under which it issues both USDC and EURC in the EU. Since then Paris has been the only supervisor for both tokens. Significance is also reassessed every year, so the label is not permanent.
Seven tests, at least three to pass
MiCA lists seven criteria in Article 43(1), and Article 56 applies the same list to e-money tokens. A token is significant when it meets at least three of them, either over its first reporting period or over at least two consecutive reports. Delegated Regulation 2024/1506 sets out how they are measured, including the two qualitative ones. Readers new to the framework can start with our guide to the MiCA regulation or the short glossary entry on MiCA.
| Criterion (Art. 43(1)) | Threshold | What is public for USDC |
|---|---|---|
| (a) Holders | More than 10 million | No EU holder count published |
| (b) Size | Value issued, market capitalisation or reserve above €5 billion | Total supply on all chains: $72.54bn (DefiLlama, 18 Oct 2026, 12:10 UTC); EU-issued share not published |
| (c) Daily transactions | More than 2.5 million transactions and €500 million a day | No EU figure published |
| (d) Gatekeeper | Issuer is a gatekeeper under the Digital Markets Act | Circle is not on the EU gatekeeper list |
| (e) International scale | Significant activity abroad, including payments and remittances | Qualitative, set by Delegated Regulation 2024/1506 |
| (f) Interconnectedness | Links with the financial system | Qualitative, set by Delegated Regulation 2024/1506 |
| (g) Other tokens and services | Issuer also issues another stablecoin and provides at least one crypto-asset service | Circle’s EU entity also issues EURC; the EBA has not said whether this test was met |
The EBA has not said which boxes USDC ticked, and neither has Circle. Coindaro’s own inference, not stated by any authority: the size test (b) looks met if global supply counts, since that supply is above $72 billion. Whether it does is open. Under Article 56(2), when several issuers issue the same token, the data is aggregated. USDC is co-issued by Circle’s US and French entities, so the global figures may have counted. The EBA has not said whether it used global or EU-only data.
What changes on 12 November: reserve, own funds and audits
Article 58(1) of MiCA is where the decision bites. Until now, Circle’s French entity has kept its reserve under Article 54 of MiCA and the safeguarding rules of the 2009 E-Money Directive. Once the token is significant, Article 58(1)(a) puts MiCA’s Articles 36, 37 and 38 in their place: how it is composed and kept separate, how it is held in custody, and how it may be invested. Article 45(1) to (4) adds four obligations: a remuneration policy, the right for different authorised custodians, including firms outside Circle’s group, to hold the token on fair, reasonable and non-discriminatory terms, a liquidity management policy, and regular liquidity stress tests. After those tests the EBA can tighten liquidity requirements.
Capital moves up a notch. As an e-money institution, Circle’s French entity has so far held own funds under Article 5 of the E-Money Directive, whose usual floor is 2% of average outstanding e-money. Article 58(1)(b) replaces that with MiCA’s own-funds rules, and Article 45(5) sets the floor at 3% of the average amount of the reserve assets. A derogation in Article 58(1) also requires an independent audit of the reserve every six months, counted from the date of the significance decision.
Then there is cash at banks. Article 54 already requires e-money token issuers to keep at least 30% of the funds received in separate accounts at credit institutions. For significant tokens the bar is higher. Article 45(7) has the EBA write technical standards on liquidity that set a minimum amount of deposits in each currency the token references, a minimum that “cannot be lower than 60 %” of the amount referenced in that currency. Circle’s 1 October paper reads this as a 60% bank-deposit minimum for significant e-money tokens, against 30% for the others. Circle has not said whether it already meets that level for its EU reserve, or whether any transition period applies.
| Requirement | Before significance | From 12 November (EBA) |
|---|---|---|
| Own funds | Usually 2% of average outstanding e-money (E-Money Directive, Art. 5) | 3% of average reserve assets (Art. 45(5) via Art. 58(1)(b)) |
| Bank deposits | At least 30% of funds (Art. 54) | At least 60% (Art. 45(7) floor, as read by Circle) |
| Reserve audit | E-money rules | Independent audit every six months (Art. 58(1)) |
| Liquidity | E-money rules | Liquidity policy and regular stress tests (Art. 45(3) and (4)) |
| Supervisor of reserve, own funds, liquidity, recovery plans | ACPR | EBA |
| Governance, shareholders, fit and proper, outsourcing | ACPR | ACPR |
The recovery and redemption plans, which Article 55 applies to all e-money token issuers, also move to the EBA for USDC. They set out how holders would be paid if the issuer failed. Around Circle the EBA will set up, manage and chair a supervisory college under Article 119, and that article lists the home authority, here the ACPR, and the ECB among its members. The college can issue opinions, which are not binding. Its exact membership and the date of its first meeting are not public, and neither is the fee the EBA may charge Circle under Article 137.
Circle argued against the deposit rule two weeks earlier
The timing is awkward for Circle. On 1 October, Patrick Hansen, its director of EU strategy and policy, published the company’s reply to the European Commission’s consultation on reviewing MiCA. The rule it criticised most is the bank deposit mandate, the same rule that becomes stricter for USDC once it is significant. In Circle’s view the mandate “increases exposure to the credit and counterparty risk of the banking sector”.
Circle asked the Commission to remove two caps: one limiting exposure to a single sovereign issuer at 35% of the reserve, and one capping deposits at any single bank at 1.5% of that bank’s total assets. It sided with the ECB on swapping the deposit mandate for a “less rigid” liquidity requirement, and it asked the EU to keep multi-issuance, the model under which the same USDC is issued by both its US and EU entities. Decrypt reported that the consultation feeds a MiCA overhaul expected in 2027.
The same submission says only three of the 25 largest stablecoins are MiCA-regulated (USDC, USDG and EURC) and that about 30 e-money tokens are authorised. The EBA counts 45 notified. The two numbers measure different things, notified tokens against authorised ones, so they do not contradict each other.
We found no statement from Circle on the classification itself on its blog or in its press room by midday on 18 October. The company has been busy elsewhere: this week it set out plans to take USDC into about 40 more emerging markets, and this morning it argued that partners already keep 59 cents of every USDC dollar of reserve income.
What it means for USDC holders and platforms in Europe
Nothing visible happens on 12 November. USDC stays redeemable at par from Circle’s EU entity under Article 49, exchanges that list it can keep doing so, and transfers work as before. The change is about the buffers behind the token and who checks them.
Those buffers get thicker on paper: more of the reserve in bank cash, a 3% capital floor, six-monthly audits and stress tests that the EBA can act on. The reserve file also moves from a national supervisor to a European one, backed by a college that includes the ECB. The interoperability rule in Article 45(2) matters to platforms, since it requires that USDC can be held by different authorised custodians on fair terms, including firms with no link to Circle.
Circle’s own counter-argument deserves a place too. A larger share of the reserve in commercial bank deposits means more exposure to the banks holding them. Whether the 60% floor makes USDC safer or simply moves the risk is the question Circle put to the Commission, and the 2027 review will have to answer it.
One set of rules applies whatever the label. Because USDC is pegged to a non-EU currency, Article 58(3) already subjects it to quarterly reporting and to the cap on its use as a means of exchange, which MiCA sets at 1 million transactions and €200 million a day. That cap, from Article 23, is not new on 12 November.
France: the ACPR keeps the licence and the governance file
For French readers, Paris loses the reserve file but keeps the licence. The ACPR remains Circle’s home supervisor for everything the EBA does not take over, and the EBA itself is based in La Défense, so the work does not leave the Paris region. The EBA’s release does not mention the AMF: Circle’s licence is an e-money institution licence, which the ACPR grants and supervises. The news comes the day after French MPs voted at first reading to tax swaps into USDC and EURC from 2027.
Italy: the same token, an EU supervisor
The EBA’s release names one national authority, France’s ACPR, as the one that keeps the rest of USDC’s supervision, because the token is issued in the EU by Circle’s French entity. It does not mention any Italian authority. For Italian holders, USDC bought on a platform in Italy is the same token issued by the same French entity, and from 12 November its reserve is watched by an EU authority instead of a French one.
EURC stays outside, far below the €5bn line
The EBA named USDC only. EURC, Circle’s euro e-money token issued by the same French entity, had €497.1 million in circulation on 18 October at 12:10 UTC, according to DefiLlama, up from €461.1 million a month earlier, a rise of about 8%. All euro stablecoins together totalled €836.2 million, which gives EURC about 59% of the segment. SG-Forge’s EURCV stood at €188.2 million and EURI at €37.2 million.
Circle describes EURC as the largest MiCA-authorised euro e-money token. It is also roughly one tenth of the €5 billion size threshold. Each token is classified on its own figures, and nothing in the EBA’s statement points to EURC following USDC.
Competition on the euro side is growing. On 14 October, the day of the EBA decision, Qivalis, a consortium of 37 European banks from 15 countries, received an electronic money institution licence from De Nederlandsche Bank. It says issuance of its euro token is planned “within the next months”. Its chief executive, Jan-Oliver Sell, said “Europe’s currency deserves Europe’s rules – on-chain”.
Dates to watch after the handover
- 11 November 2026: issuers’ third-quarter reports, with data at 30 September, are due on the EBA’s reporting platform, according to its reporting calendar.
- 12 November 2026: the EBA takes over USDC’s own funds, reserve, liquidity and recovery and redemption plans.
- Six-monthly from the decision: independent audits of the USDC reserve.
- January 2027: ESMA’s deadline for EU platforms to stop offering stablecoins that are not MiCA-authorised.
- 18 January 2027: the US GENIUS Act takes effect.
- 2027: the Commission’s MiCA review, to which Circle sent its deposit-rule objections.
- October 2027: the EBA’s annual reassessment of whether USDC is still significant.
Several answers are still missing: which criteria USDC met, whether the EBA counted global or EU data, who sits on the college, how much Circle will pay in fees, and whether Circle gets time to reach the 60% deposit floor. The first public signs should come from the college and from Circle’s next reserve reports after 12 November.