TLDR
- Circle urged European regulators to relax MiCA’s stablecoin reserve mandates, particularly the 30%-60% bank deposit threshold.
- Hyperliquid Policy Center advocates for perpetual futures to fall under MiFID II regulations rather than MiCA.
- According to Circle, just three stablecoins among the global top 30 comply with existing MiCA requirements.
- The European Central Bank supports reducing the mandatory bank deposit floor for stablecoin providers.
- September 30 marked the deadline for the European Commission’s MiCA review consultation submissions.
Two prominent crypto entities—Circle and the Hyperliquid Policy Center—have formally petitioned European Union authorities to modify critical components of the Markets in Crypto-Assets Regulation (MiCA). Their proposals were submitted as part of the European Commission’s ongoing regulatory review process.
🇪🇺 We submitted feedback to the European Commission’s MiCA Review Consultation
As the largest MiCA-regulated e-money token (EMT) issuer for both the dollar (@USDC) and the euro (EURC), and having been the first major global issuer to comply back in July 2024, @circle knows… pic.twitter.com/YvEME8czAr
— Patrick Hansen (@paddi_hansen) October 1, 2026
The public consultation window concluded on September 30, with numerous organizations filing their recommendations in the days leading up to the cutoff date.
Circle, the organization behind the USDC stablecoin, concentrated its filing on the regulation’s reserve mandate provisions. The firm contends that existing requirements compel stablecoin operators to maintain excessive cash holdings within traditional banking institutions.
MiCA’s current framework mandates that issuers preserve a minimum of 30% of their reserves as bank deposits. This threshold escalates to 60% for stablecoins designated as “significant” by the European Banking Authority.
Circle argues this structure amplifies vulnerability to banking sector instability. The company referenced its own March 2023 incident, when USDC temporarily departed from its dollar peg following the entrapment of $3.3 billion in reserves at the collapsed Silicon Valley Bank.
Circle Pushes for Reserve Framework Revision
According to Circle’s analysis, merely three among the world’s 30 largest stablecoins presently satisfy MiCA compliance standards. These compliant tokens are USDC, USDG, and EURC.
The firm advocates replacing the mandatory bank deposit minimum with a liquidity-oriented framework. This alternative approach would emphasize asset convertibility speed over storage location.
The European Central Bank has expressed alignment with this perspective. It suggested requiring a reserve portion to reach maturity within one to five business days as an alternative to bank deposit requirements.
Circle further requested that European authorities preserve the multi-issuance model. This arrangement permits a MiCA-authorized entity to distribute a stablecoin in conjunction with an international affiliate under a unified global trademark.
The company cautioned that eliminating multi-issuance capabilities might drive consumers toward non-EU stablecoins operating beyond European regulatory jurisdiction. It referenced the Commission’s 2020 evaluation, which identified identical risks.
Circle also urged regulators to eliminate two specific technical restrictions. One constraint limits reserve exposure to any single government entity at 35%. The other caps exposure to individual banks at 1.5% of that institution’s aggregate assets.
Hyperliquid Challenges Perpetual Futures Classification
The Hyperliquid Policy Center submitted an independent response addressing perpetual futures contracts, commonly referred to as perps. The organization advocates for classifying these instruments under MiFID II, the European Union’s established derivatives regulatory framework implemented in 2014.
The center maintained that perpetual futures should be evaluated based on their economic characteristics rather than their underlying technological infrastructure. It asserted that existing MiFID II classifications adequately encompass these financial products without requiring additional legislative measures.
The organization additionally requested that European regulators refrain from applying contracts-for-difference regulatory standards to perpetual futures. It emphasized fundamental operational differences, noting that perps function through transparent order books rather than bilateral counterparty arrangements.
Additional industry participants contributed responses to the consultation. Deutsche Börse Group recommended establishing a distinct classification for stablecoins utilized within settlement infrastructure. Chamber of Progress endorsed preserving multi-issuance frameworks and permitting interest distributions on e-money tokens.
The European Commission has yet to announce a schedule for subsequent action following the consultation period.
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