Stablecoin Reserves: Why the ECB Wants the Bank Deposit Rule Scrapped

On September 22, 2026, the European System of Central Banks published its response to the European Commission’s review of MiCA. The core of the 61-page opinion concerns anyone holding a euro or dollar stablecoin directly: the central banks consider the obligation to park a fixed share of reserves as a bank deposit a design flaw, and propose replacing it with liquidity requirements.

One point up front, so the context is right. No rule changes on September 30. That date merely marks the end of the window in which the Commission accepts responses to the MiCA review. What you can check on your own stablecoin today is already settled, and that is what this article is about.

What the ESCB submitted to the MiCA review

The European System of Central Banks, or ESCB, is the network formed by the European Central Bank and the national central banks of the EU, which in Germany means the Bundesbank. Its contribution to the consultation is a technical opinion rather than legislation: the ESCB sets out what it regards as problematic in the current wording of the regulation, and it names alternatives.

We downloaded the document ourselves and read it in full. It sits as a PDF on the ECB’s website. The section at issue here asks what the deposit requirement means for banks, for financial stability and for monetary policy. The ESCB draws an explicit distinction between stablecoins that track the euro or another EU currency and those referencing non-EU currencies, because the consequences differ in each case.

We set out the framework of this consultation, and what you can submit yourself before the deadline, in the MiCA consultation that closes on September 30. This article takes on the weightiest substantive contribution received since then.

The 30 percent rule: what MiCAR requires today

An e-money token, EMT in the language of the regulation, is a crypto asset that tracks the value of a single official currency. An asset-referenced token, or ART, refers instead to a basket of currencies, commodities or other assets. Under the regulation, both have to hold a reserve that covers redemption at par at all times.

The decisive requirement is quoted verbatim in the opinion. At least 30 percent of reserve assets must be held as deposits with credit institutions, rising to 60 percent for tokens classified as significant. The remainder has to go into safe, low-risk assets that qualify as highly liquid instruments with minimal market, credit and concentration risk, and those assets must be capable of being sold quickly without a large price impact.

“Significant” here is not a matter of judgement but a classification by the supervisor, based on thresholds such as user numbers, the amount in circulation and transaction volume. That classification doubles the deposit share, and this is where the central banks’ criticism begins: the larger a stablecoin grows, the more tightly it is chained to the banking system. Which issuers are authorised in Europe at all is covered in our piece on the MiCA register of stablecoin issuers.

Why central banks consider the deposit requirement risky

The ESCB argument fits into a single sentence: the obligation to hold a set share of the reserve as a bank deposit creates a direct link between issuers and credit institutions, and that link transmits stress in both directions.

The first direction runs from the stablecoin to the bank. If a run develops on a single token, the issuer has to pull its deposits quickly in order to meet redemption requests. With a large token, the sudden withdrawal of a substantial sum can put the bank concerned in difficulty. The opinion records that such effects first hit individual institutions and can then turn systemic. On top of that, deposits from stablecoin issuers are considered less stable and react more sensitively to changing conditions than ordinary customer deposits.

The second direction runs from the bank to the stablecoin, and there is a documented case for it, which the next section deals with.

SVB and USDC: how the coupling worked in March 2023

The ESCB cites the events of March 2023 as evidence. Silicon Valley Bank, and with it part of the US regional banking sector, ran into trouble at the time. The issuer of the dollar stablecoin USDC held part of its reserve at that bank. Once that became known, it triggered a run on the token, which slipped well below a dollar for a period.

The lesson the central banks draw from it is the decisive one: a bank deposit is not a risk-free parking space. A deposit is a claim against a credit institution, and in a crisis the supposedly safest part of the reserve becomes the most contagious. Holders who want to understand how close the link between euro stablecoins and banks has become will find it in our piece on euro stablecoins and the banks behind them.

At the same time, the ESCB concedes that deposits do achieve something. The amount held forms a liquidity buffer that can be tapped in periods of stress, and it spares the issuer a forced sale of securities below book value. The question is therefore not whether liquidity is needed, but in what form it is held.

What should replace it: repos and short-dated government bonds

This is where the opinion becomes concrete. The ESCB names three ways for an issuer to achieve the same liquidity, or better, without a fixed deposit ratio.

First, reserve assets can be pledged in repo transactions: the security is handed over against cash and bought back later, which creates short-term liquidity without disposing of the holding. Second, the ESCB names overnight reverse repos as an alternative to the deposit. These transactions are concluded overnight and therefore mature daily, which secures a continuously available pool of funds for redemption requests. Third, it points to short-dated government bonds, which issuers can buy in the secondary market or directly at auction; large euro area countries routinely issue paper with maturities of three to twelve months.

The common denominator: instead of a rigid ratio, thresholds tied to the availability of funds should apply, such as what share of the reserve can be turned into cash within one business day and what share within five. That is the logic familiar from banking supervision, transferred to stablecoin issuers.

The two missing standards: why parts of the rules do not yet bite

One finding in the opinion gets lost in the headlines, although in practice it is the most important. Two technical regulatory standards drawn up by the European Banking Authority under the mandate of the regulation have so far not been endorsed by the European Commission. The ESCB writes that certain aspects of the liquidity requirements are therefore not yet applicable or not sufficiently clear, and it explicitly supports the adoption of those standards.

Two obligations are affected that you feel directly as a holder when they are absent: the requirement to limit concentration risk, and the issuer’s duty to monitor the creditworthiness of the banks where it maintains its deposits. Those two points are precisely what would have made the difference in the 2023 case. For as long as the standards are not in force, the rule relies on the issuers’ own initiative.

For context, that means the regulation applies but is unfinished at this point. Anyone wanting to read up on the changes to MiCA already planned will find the overview in our guide to the obligations the regulation imposes on crypto firms.

What this means for you as a holder of EURC or USDC

None of these questions changes anything about your balance today. Taken together, though, they change what you look at when you park a larger amount in a stablecoin.

The first point is the composition of the reserve. An issuer with 60 percent sitting at banks depends on the health of those banks; one with a high share of short-dated government bonds carries interest rate and market risk instead, which stays small at short maturities. The second point is spread: does the deposit sit with a single institution or with several? The third is whether you can demand redemption at par directly from the issuer, or only exit through the trading venue, where the price can deviate in periods of stress.

Holders who keep their stablecoins with a provider authorised in the EU have the shorter route to an answer on these questions, because the reporting duties apply there. Which houses hold a MiCA authorisation is shown in our comparison of regulated crypto exchanges.

How to check your stablecoin’s reserve yourself

This sounds like work for supervisors, but it takes a quarter of an hour. Issuers that fall under the regulation have to publish a crypto-asset white paper and report regularly on the composition of the reserve. Both sit on the issuer’s website, usually under transparency or reserve.

What to look for: how large is the share held as a bank deposit, and is it spread across several institutions? What residual maturities do the securities in the reserve carry, and are they government bonds or other paper? How old is the most recent report, and who audited it? If you cannot find the figures, or they date from the quarter before last, that is an answer in itself.

A second point, often forgotten: check which version of a token you actually hold. Some dollar stablecoins exist in an EU-compliant and a non-European variant, in part issued on different networks. The reserve rules of the regulation apply only to the version issued in the EU.

The September 30 deadline: what happens afterwards and what does not

The targeted consultation on the review of the MiCA regulation has been running since May 20, 2026. The Commission accepts responses until September 30, 2026 at 23:59 CEST; the deadline was originally set to expire at the end of August and was extended. Both details sit on the Commission’s consultation page, which we called up ourselves.

Any individual and any company may take part, not only trade associations. So if you are affected yourself, because you use stablecoins or settle payments in them as a business, that is the route by which your experience feeds into the review. Eight days is tight, but enough for a considered answer to individual questions.

What does not happen afterwards matters just as much: no new rule applies on October 1. The responses feed into the reports the Commission has to deliver under Articles 140 and 142 of the regulation, and those reports are due by mid-2027. A change in the law would then require the ordinary procedure involving Parliament and Council. Anyone telling you the deposit requirement is about to fall is selling you an expectation as a fact.

How likely is it that the rule really falls?

That question cannot be answered today, and we will not pretend otherwise. What can be said: an opinion from a central bank carries weight in a procedure of this kind, but it does not bind the Commission. Other participants in the consultation hold opposing positions, and alongside the stability argument the deposit requirement has a monetary policy one: reserves held at European banks stay within the European circuit.

A middle path is the realistic outcome: a lower ratio, combined with liquidity thresholds and the two technical standards still outstanding. For you as a holder, that changes little in daily use, but a fair amount about how resilient a stablecoin is under stress. Which is exactly why it pays to keep an eye on the reserve reports rather than wait for the legislator.

Stablecoin reserves: what to take away

1. Look at the most recent reserve report for your stablecoin. Note the share of bank deposits, the number of institutions and the residual maturities of the securities. If you want to check at the same time whether your own provider is authorised in the EU, the context is in our comparison of regulated crypto exchanges.
2. Spread larger stablecoin holdings instead of keeping everything in one token. The link to individual banks is the weak point the central banks name themselves; spreading your holdings makes you independent of any single issuer. Where each token can be traded in euros is shown in the exchange comparison.
3. Use the deadline if the subject affects you. The Commission accepts responses until September 30 at 23:59 CEST; after that, how the reserve rules look in future is decided without you. The framework and the questions are set out in our overview of MiCA obligations.

Sources for further reading: the ESCB opinion on the MiCAR review as a PDF, and the European Commission consultation page with the deadline and the questionnaire.

(As of September 22, 2026. This article is not investment advice. Prices and fee structures change; check the terms with the provider before you buy.)