
The EU called USDC significant. That means 60% in bank deposits.
The EBA named USDC the EU's first significant stablecoin on October 14. The label lifts its bank-deposit floor from 30% to 60%, the risk that broke it in 2023.
By the numbers
The European Banking Authority named USDC the first "significant" e-money token in the EU on October 14, 2026, out of 45 tokens notified under MiCA. From November 12 the EBA, rather than France's ACPR, supervises the token's capital, reserve, liquidity and redemption plans.
The label carries a reserve rule most coverage skipped. Under the EBA's technical standard, an issuer of a significant e-money token must hold at least 60% of the reserve as deposits with credit institutions, against 30% for an ordinary one. On October 8, bank deposits were $10 billion of USDC's $73.2 billion reserve, about 13.7%. The rest sat in Treasury repos and short Treasury bills.
So the EU's stamp of systemic importance pushes the EU-issued part of USDC toward more bank cash. Bank cash is what broke the peg in 2023, when $3.3 billion of a roughly $40 billion reserve sat at Silicon Valley Bank and USDC fell to $0.88. Circle itself argued two weeks ago that the floor raises that risk.
What the EBA decided on October 14
The decision covers USDC as issued by Circle Internet Financial Europe SAS, Circle's French e-money institution. The same token is issued in the US by Circle Internet Financial, LLC, which is why the EBA signed a cooperation agreement with New York's Department of Financial Services.
Supervision splits in two from November 12:
- The EBA takes own funds, the reserve of assets, liquidity requirements, and the recovery and redemption plans.
- The ACPR keeps governance, qualifying holdings and fit-and-proper checks.
The EBA's release did not say which of MiCA's significance criteria USDC crossed, and it gave no timetable for meeting the stricter rules. The EBA reviews significance once a year, so the label can also be lifted.
The three rules that change for a significant token
Bank deposits go from 30% to 60%. Article 3 of the EBA's liquidity standard sets the floor per currency referenced. USDC references the dollar, so the floor is 60% of the reserve in dollar deposits.
Liquidity tightens. For a significant token, at least 40% of the reserve must be withdrawable on one working day's notice, and at least 60% within five working days. An ordinary token needs 20% and 30%.
Capital goes from 2% to 3%. MiCA's Article 45(5) sets own funds at 3% of the average reserve for a significant token instead of 2%, and Article 58 applies it to e-money institutions. That is $30 million of capital per $1 billion of reserve, up from $20 million.
The same standard caps how much can sit in any one bank: 25% of the reserve at a systemically important bank, 15% at another large bank, 5% anywhere else, and never more than 1.5% of the bank's own total assets.
How far USDC's reserve sits from 60%
Here is the full reserve on October 8, from Circle's transparency data as reported for the week of October 1 to 8:
View as table
| label | USDC reserve by asset, October 8, 2026 |
|---|---|
| Treasury reverse repos | $36.3B |
| Treasury bills under 3 months | $26.9B |
| Deposits at systemically important banks | $9.3B |
| Other bank deposits | $0.7B |
Bank deposits total $10 billion. That is the group-wide reserve, US and EU issuance together. Circle doesn't publish how much USDC its French entity has issued, and the 60% floor applies only to that part.
Our read, as an upper bound: if the floor applied to all $73.2 billion, deposits would need to reach $43.9 billion, more than four times today. The real figure is smaller and unknown. The direction is certain. For every dollar of EU-issued USDC, Circle must move at least 46 cents more from Treasury paper into bank accounts than the group as a whole holds today.
Why Circle says the rule adds risk
Circle filed its answer to the European Commission's MiCA review on October 1. It said the deposit floor "increases exposure to the credit and counterparty risk of the banking sector" and asked for a looser liquidity rule based on how fast assets mature in one to five working days. It also said the 1.5% per-bank cap forces large issuers to deal with "dozens of separate banks".
Circle isn't alone. The European Central Bank and the national central banks also called for scrapping the deposit minimums in favour of a maturity rule.
The argument rests on 2023. Silicon Valley Bank held about 8% of USDC's reserve when it failed. That was enough to knock the token 12% below its peg over a weekend. A Treasury bill held in custody doesn't vanish when a bank fails. A deposit above the insured limit can be frozen.
The case for the rule
The EU's reasoning has a point too. Deposits pay out on demand at par, while a Treasury bill sold in a panic can fetch less than face value. The concentration caps answer the SVB problem directly: no single bank can hold more than 25% of the reserve, and a small bank no more than 5%. Under those caps, no single bank failure can reach more than a quarter of the reserve.
So the risk changes shape. One bank failing hurts less. A stress that hits many banks at once, the kind that comes with a recession, hurts more, because more of the reserve depends on banks.
Who this matters for
If you hold USDC through an EU exchange or wallet, your token and its redemption terms don't change on November 12. What changes is who checks the reserve behind it.
If you run treasury in USDC, read Circle's monthly attestations from December onward for one figure: the bank-deposit share of the EU reserve. If Circle publishes it, you'll see whether it has started to move. If it doesn't, ask.
Two dates to watch. November 12, when the EBA takes over. And June 30, 2027, when the Commission reports on how MiCA is working, the next formal chance to change the 60% floor. If you're holding USDT on an EU exchange, the January 8 custody deadline comes first. On the US side, the Fed has already put a price on the stablecoin dollar.
Sources
- EBA: USDC classified as first significant e-money token, October 14, 2026
- EBA final report, RTS on liquidity requirements of the reserve of assets (Article 36(4) MiCA)
- MiCA Article 45 and Article 58
- USDC circulation and reserve, October 1 to 8, 2026
- The Block: Circle and Hyperliquid press the EU in the MiCA review, October 1, 2026
- crypto.news: Circle wants the EU to ease MiCA bank deposit rules
- The Block: USDC at about $0.90 after Circle disclosed SVB funds, March 11, 2023
- EBA classifies USDC as the first significant EMT: dates and articles
This is not financial advice.
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