EBA Classifies USDC as Significant Electronic Money Token
The European Banking Authority (EBA) has announced that USDC, issued by Circle Internet Financial Europe SAS, has been classified as a significant electronic money token (EMT) under the Markets in Crypto-Assets Regulation (MiCA).
Currently, there are 45 EMTs notified under MiCA in the EU, with USDC being the first classified as significant.
Starting from November 12, 2026, USDC will be subject to dual regulation under MiCA for significant EMTs. Direct regulatory responsibilities regarding own funds, asset reserves, liquidity requirements, and recovery and redemption plans will be transferred from the French Prudential Supervision and Resolution Authority (ACPR) to the EBA.
The ACPR will still be responsible for governance, qualified holdings, suitability assessments, outsourcing, and conflicts of interest.
USDC is issued in the EU by Circle Internet Financial Europe SAS and in the US by Circle Internet Financial, LLC.
The EBA has signed a memorandum of understanding with the New York State Department of Financial Services to facilitate cooperation and information exchange regarding cross-border stablecoin activities.
Who is buying: EU compliant issuers and institutional investors using the MiCA framework. Who is selling: Circle maintains the issuance and circulation of USDC within the EU through its EU entity. Event-driven: The scale reaching the MiCA "significant" threshold triggers regulatory upgrades. Fund flows are subject to direct EBA oversight regarding reserves and liquidity arrangements. Beneficiaries are compliant stablecoins that have completed MiCA notification; those under pressure are issuers that do not meet compliance or face stricter reserve requirements.
Source: Public information
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Circle has previously obtained an electronic money institution license from the ACPR in France to issue USDC and EURC under the MiCA framework and has completed the relevant notifications in the EU. Historically, the company has operated stablecoins through a multi-jurisdictional entity structure, with the US entity regulated by the New York State Department of Financial Services and the EU entity operating under the French framework.
In terms of capital pathways, Circle separates EU issuance from US issuance, maintaining compliance status within the EU through its EU entity while coordinating with US regulators. Resources are focused on meeting reserve, liquidity, and redemption arrangement requirements to address the higher prudential standards brought by the "significant" rating. The motivation is to retain the accessibility of the US dollar stablecoin in the EU market and avoid exclusion from compliant distribution channels due to non-compliance.
Similar cases include other stablecoin structures issued simultaneously in multiple jurisdictions and precedents of banks accepting higher regulatory standards after systemically important ratings. The current industry is in a phase of regulatory change, with the implementation of MiCA shifting tokens that meet the threshold from single member state regulation to dual regulation by the EU and member states.
Essentially, this represents a shift in regulatory change and pricing power. After the scale threshold is triggered, direct regulatory authority over key prudential matters shifts from member state authorities to the EBA, subjecting the reserves and liquidity arrangements of large stablecoins to more centralized EU-level constraints. The mechanism is to incorporate financial stability-related risks into higher-level supervision through the "significant" classification while retaining local control over governance and holdings for member states, altering the cost and access structure for compliant issuers.
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