EBA classifies USDC as the first significant e-money token under MiCA

On 14 October 2026 the European Banking Authority announced that it has classified USDC, issued by Circle Internet Financial Europe SAS, as a significant e-money token (EMT) under the Markets in Crypto-Assets Regulation, Regulation (EU) 2023/1114 (MiCA). In the EBA's words, "There are currently 45 EMTs in the European Union, which have been notified under MiCA, and USDC is the first one to be classified as being significant."

From 12 November 2026 USDC comes under the dual supervision that MiCA provides for significant EMTs. Direct supervision of the issuer's own funds, reserve of assets, liquidity requirements and recovery and redemption plans moves from the French Autorité de Contrôle Prudentiel et de Résolution (ACPR) to the EBA. The ACPR stays responsible for governance, qualifying holdings, fit and proper assessment, outsourcing and conflicts of interest, and the two authorities will work together on the transition.

USDC is issued in the EU by Circle Internet Financial Europe SAS and in the United States by Circle Internet Financial, LLC. To support its supervision of cross-border stablecoin activity, the EBA has signed a memorandum of understanding with the New York State Department of Financial Services on cooperation and the exchange of information.

Under Article 56 of MiCA the EBA classifies an e-money token as significant where at least three of the seven criteria in Article 43(1) are met, either in the period covered by the first report after the token is offered to the public or in at least two consecutive reports. The criteria are more than 10 million holders; a value issued, market capitalisation or reserve of assets above EUR 5 billion; more than 2.5 million transactions and EUR 500 million a day on average; an issuer designated as a gatekeeper under the Digital Markets Act; the significance of the issuer's activities on an international scale, including use of the token for payments and remittances; its interconnectedness with the financial system; and an issuer that issues at least one other token and provides at least one crypto-asset service.

Commission Delegated Regulation (EU) 2024/1506 sets the indicators for this assessment, and the EBA's Decision EBA/DC/558 sets the procedure. The EBA reassesses every significant token once a year and can declassify it, in which case supervision returns to the home authority. The press release does not say which criteria USDC met.

Under Article 117(4) of MiCA the EBA supervises whether an e-money institution issuing a significant e-money token complies with Article 55 (recovery and redemption plans) and Article 58. Article 58(1) applies MiCA requirements instead of Articles 5 and 7 of the E-Money Directive (Directive 2009/110/EC). They cover the reserve of assets, its custody and investment (Articles 36 to 38), a remuneration policy, a liquidity management policy with regular liquidity stress testing, and own funds of at least 3% of the average reserve assets. The issuer must also make sure the token can be held in custody by different authorised CASPs, including CASPs outside its group, on a fair, reasonable and non-discriminatory basis. The independent audit of the reserve becomes six-monthly from the date of the classification decision.

Within 30 calendar days of the classification decision the EBA must set up and chair a supervisory college for the issuer (Article 119). Its members include ESMA, the ECB, the home authority and the competent authorities of the most relevant CASPs, credit institutions or investment firms holding the reserve assets or the funds received for the token, of the most relevant trading platforms where it is admitted to trading, of the most relevant payment service providers and of the most relevant custody CASPs. Authorities of Member States where the token is used at large scale may join at their request, and any other competent authority may ask the college for information.

The EBA's announcement sets no new obligation for CASPs or e-money institutions in Cyprus. It does not restrict the offer, trading or custody of USDC, and it says nothing about which firms or authorities will sit in the supervisory college.

CASPs should still expect contact from the issuer. Under Decision EBA/DC/558 the issuer of a newly significant token must send the EBA information for setting up the college within 10 calendar days of notification of the final decision, and part of it is data the issuer requests from CASPs on the most relevant payment service providers used with the token. Separately, Article 58(3) of MiCA applies the Article 22 reporting rules to e-money tokens denominated in a currency that is not an official currency of a Member State. Where they apply, CASPs that provide services related to the token give the issuer the data it needs for its quarterly report. Under these MiCA reporting rules, the EBA explains, CASPs are required to report data on tokens held to issuers every day and quarterly data by fixed dates, the next being 21 October 2026. For the MiCA framework, see our study note on registration and MiCA, and for the conduct and custody rules see our note on CASP organisational requirements.

E-money institutions that issue tokens can see here what significance would bring: EBA supervision of reserves, own funds, liquidity and recovery planning, a supervisory college and six-monthly reserve audits. Under Article 58(2) the home supervisor may also require an e-money institution issuing a token that is not significant to meet any of the Article 58(1) requirements where needed to address the risks they target, such as liquidity, operational or reserve-management risks.