USDC’s EU Reserves and Capital Shift to EBA Supervision in MiCA’s First ‘Significant’ Call

Circle’s European USDC issuer will answer to the European Banking Authority (EBA) on reserves, liquidity and capital from Nov. 12, after the regulator deemed the dollar stablecoin a significant e-money token under MiCA, Europe’s Markets in Crypto-Assets Regulation.

The EBA disclosed the decision on Oct. 14. According to the agency, 45 e-money tokens (EMTs) have been notified under MiCA across the bloc, and “USDC is the first one to be classified as being significant.”

The release did not say which of MiCA’s significance criteria USDC met, and it gave no figures on the token’s size. The EBA reviews each classification once a year.

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Circle’s European arm, Circle Internet Financial Europe SAS, is the token’s EU issuer and holds an electronic money institution license from France’s banking and insurance supervisor, Autorité de Contrôle Prudentiel et de Résolution, known as the ACPR. Circle, which went public in June 2025, said in July 2024 that the French license made it the first global stablecoin issuer to comply with MiCA.

Under the “dual supervision” MiCA sets for significant EMTs, the EBA will take charge of the issuer’s capital requirements, its asset reserve, its liquidity, and its plans for recovery and redemption. The ACPR keeps oversight of governance, qualifying holdings, fit-and-proper checks, outsourcing and conflicts of interest. The EBA said in its release that the two supervisors “will work closely together to ensure a smooth transition and effective supervisory cooperation.”

In the U.S., USDC is issued by Circle Internet Financial, LLC. The EBA also cited a memorandum of understanding it signed with the New York State Department of Financial Services, made public in June, for sharing information on cross-border stablecoin activity.

The decision comes two weeks after Circle filed its response to the European Commission’s review of MiCA. In that Oct. 1 post, Circle wrote that MiCA requires EMT issuers to hold at least 30% of reserves as commercial bank deposits, a floor that rises to 60% for issuers of significant tokens.

Circle said the deposit rule “increases exposure to the credit and counterparty risk of the banking sector,” and backed swapping it for a looser liquidity standard.

The EBA’s release did not address the deposit requirement. Circle had not published a statement on the classification as of publication.

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