EBA Takes Over Reserve, Liquidity and Capital Supervision of USDC as MiCA Dual Oversight Begins

From 12 November 2026, the European Banking Authority (EBA) directly supervises key parts of USDC, the dollar stablecoin issued in the European Union by Circle Internet Financial Europe SAS. It is the first time an EU-level authority has taken over supervision of a stablecoin under the Markets in Crypto-Assets Regulation (MiCA, Regulation (EU) 2023/1114). The handover follows the EBA's decision, announced on 14 October 2026, to classify USDC as the first significant e-money token (EMT) among the 45 EMTs notified in the EU.

From this date, supervision of USDC's own funds, reserve of assets, liquidity requirements and recovery and redemption plans moves from France's Autorité de Contrôle Prudentiel et de Résolution (ACPR) to the EBA. The ACPR stays responsible for governance, qualifying holdings, fit and proper assessments, outsourcing and conflicts of interest.

What the Significant Classification Means Under MiCA

MiCA lets the EBA classify an e-money token as significant when at least three criteria in Article 43(1) are met. These include more than 10 million holders; a token value, market capitalisation or reserve above EUR 5 billion; more than 2.5 million transactions and EUR 500 million in daily transaction value; international use for payments and remittances; interconnectedness with the financial system; and an issuer that also issues other tokens and provides at least one crypto-asset service. Article 56 sets the procedure. The EBA notifies a draft decision, the issuer and its national supervisor have 20 working days to comment, and the final decision must follow within 60 working days. Supervisory responsibilities then pass to the EBA within 20 working days of the notification of that decision. The EBA's 14 October press release did not say which criteria USDC met.

For a significant EMT issued by an electronic money institution, MiCA does not hand the whole issuer to the EBA. Article 117(4) says the EBA supervises compliance with Articles 55 and 58 only, and the national authority keeps everything else. The EBA describes this as dual supervision. Article 55 applies MiCA's recovery and redemption plan rules to EMT issuers. Under Article 58, an electronic money institution issuing a significant EMT follows the reserve rules for asset-referenced tokens (Articles 36 to 38) instead of the safeguarding rules of the E-Money Directive. It must also meet the extra duties for significant tokens in Article 45(1) to (4): a remuneration policy, custody available through different crypto-asset service providers on fair, reasonable and non-discriminatory terms, a liquidity management policy and regular liquidity stress testing.

Own funds are calculated under Article 35 with the higher percentage set by Article 45(5), 3% of the average amount of reserve assets. Article 58 also requires an independent audit of the reserve every six months, counted from the date of the classification decision. In its 14 October release, the EBA said it would work with the ACPR to ensure a smooth transition.

Who Is Affected

The direct addressee is Circle Internet Financial Europe SAS, the EU issuer of USDC, which is supervised in France by the ACPR. The EBA notes that USDC is issued in the United States by a separate entity, Circle Internet Financial, LLC. To support supervision of this cross-border activity, the EBA has signed a Memorandum of Understanding with the New York State Department of Financial Services covering cooperation and the exchange of information.

For crypto-asset service providers that list or hold USDC, the classification does not change the token's legal status. USDC remains an e-money token that can be offered in the EU under MiCA. What changes is which authority checks the reserve, capital and liquidity behind it. Providers already have reporting duties that feed the EBA's work. MiCA Article 22 and the EBA's reporting framework require providers to report daily token holdings to issuers, and issuers report quarterly to the EBA. On the EBA's published calendar, the issuer remittance for the third quarter of 2026 was due on 11 November 2026, the day before the handover.

The other 44 notified EMTs, including Circle's euro token EURC, are not classified as significant and stay with their national supervisors. Under Article 58(2), a national authority may still apply some of the significant-token requirements to a non-significant EMT where it sees liquidity, operational or reserve-management risks.

What Comes Next

For each issuer of a significant token, the EBA sets up, manages and chairs a supervisory college. Under MiCA, these colleges bring the relevant authorities together and issue non-binding opinions on specific matters. The EBA says it runs both off-site supervision, which is day-to-day monitoring, and planned on-site inspections of the issuers it supervises.

The classification is not permanent. Article 56(8) requires the EBA to reassess every year whether a significant EMT still meets the criteria. If it no longer does, the EBA must follow the same draft-decision and comment procedure before removing the label. Further classifications are possible if other EMTs cross three of the thresholds in the reports that national authorities send to the EBA at least twice a year.

For market participants, USDC's reserve and liquidity arrangements in the EU now answer to a single EU authority applying MiCA's stricter significant-token rules. Firms reviewing their stablecoin exposure should read the EBA decision together with the issuer's MiCA white paper and the EU register of EMT issuers.