The European Banking Authority has asked the Commission’s MiCA review to address third-country multi-issuer stablecoins and crypto lending, including services that give customers access to decentralised lending protocols. Its 24 September response supports the core asset-referenced token and e-money token issuer framework while identifying specific gaps in scope and supervision.[1]
These are recommendations to the Commission. Changes beyond the existing MiCA text require legislation or other formal measures; current MiCA, technical standards and other applicable EU or national rules continue to govern in the meantime.[1][2]
EBA priorities for the MiCA review
| Area | Current assessment | Recommended review |
|---|---|---|
| ART and EMT issuer framework | Broadly appropriate | Preserve core framework while addressing identified gapsSource 1 |
| Third-country multi-issuer schemes | Significant to very significant risks | Strengthen the regulatory treatmentSource 1 |
| Reserve deposits | Existing prudential framework applies | Review minimum deposit share without weakening risk managementSource 1 |
| Crypto-asset classification | Costly and inconsistent at the boundaries | Clarify MiCA scope and definitionsSource 1 |
| Crypto lending and DeFi access | Not comprehensively addressed as a standalone service | Consider a regulated perimeter and consumer safeguardsSource 1 |
| Reporting | Implementation experience now available | Review issuer and service-provider reportingSource 1 |
A common token can span several legal obligations
A token can present one brand and redemption promise while issuance, reserves and distribution span different legal entities and countries. The EBA’s concern is that third-country multi-issuer models can make the responsible issuer, reserve location and redemption obligation harder to supervise consistently.[1]
The supervisory task is to connect the customer’s redemption right to the responsible issuing entity, its reserve assets and the authorities able to enforce those obligations. The EBA’s cooperation memorandum with the New York State Department of Financial Services already provides for information exchange and coordination on international stablecoin activities, illustrating the cross-border relationships behind the review.[1][3]
Market context at the review point
| Measure | Value | Context |
|---|---|---|
| MiCA stablecoin provisions | Applicable since 30 June 2024 | ART and EMT issuer rules preceded the wider CASP regime.Source 2 |
| Most other MiCA provisions | Applicable since 30 December 2024 | The review now has early supervisory experience to examine.Source 2 |
| EBA role | Direct supervision of significant ARTs; dual supervision for significant EMTs | National authorities retain specified responsibilities for significant EMT issuers.Source 2Source 3 |
Lending brings the intermediary’s role into focus
Crypto lending is not named as a standalone service in MiCA’s current list. The EBA recommends considering a perimeter for CASPs that intermediate lending or facilitate client access to DeFi lending protocols. The proposed focus on the service provider’s role would require distinguishing custody and transfers from arranging or intermediating credit.[1][2]
A lending service can expose customers to collateral calls, changes in interest rates, counterparty default, protocol failures and loss of access. Those risks can exist whether the user meets a centralised lender directly or reaches a decentralised protocol through a regulated interface. The EBA’s recommendation focuses on the intermediary role and consumer impact rather than labelling all decentralised software the same way.[1]
A future framework would need to address the service’s terms as well as its perimeter: collateral calls and liquidation, interest and fees, variable pricing, responsibility for protocol access and data for supervisors to assess concentration and customer harm. Classification also needs to establish where MiCA ends and MiFID, CRD or other EU law applies.[1]
For brokers and platforms, the useful mapping is by entity, customer route and legal role. That connects a lending or yield feature to the permission and obligations relevant to the service, and a stablecoin holding to the entity responsible for redemption. The Commission’s review and any subsequent proposal will determine the eventual scope, transition and prudential treatment.[1]
Sources & further reading
- The EBA identifies priorities for the review of MiCA European Banking Authority · 24 Sep 2026 · Accessed 16 Oct 2026
- Asset-referenced and e-money tokens: MiCA publications European Banking Authority · Accessed 16 Oct 2026
- EBA and NYDFS sign cooperation agreement for international stablecoin supervision European Banking Authority · 2 Jun 2026 · Accessed 16 Oct 2026