The European System of Central Banks has proposed changing one part of MiCA’s stablecoin reserve framework. In its 22 September response, it suggested replacing minimum bank-deposit shares with required proportions of reserve assets maturing within one and five working days. This is a consultation proposal, not an adopted rule. European System of Central Banks: response to the MiCA review consultation, September 2026
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Maturity buckets could focus the reserve rule on redemption access while reducing reliance on fixed deposit percentages.
Maturity buckets could focus the reserve rule on redemption access while reducing reliance on fixed deposit percentages.
Until EU lawmakers act, current MiCA reserve rules continue to govern affected issuers.
MiCA currently sets deposit floors; the ESCB recommends maturity buckets
The ESCB response describes the existing MiCA requirement that at least 30% of reserve assets for covered tokens be deposits at credit institutions, rising to 60% for significant ARTs and EMTs. The remaining reserve is subject to requirements for secure, low-risk and highly liquid instruments. These are the current statutory thresholds discussed in the response. European System of Central Banks: response to the MiCA review consultation, September 2026
The central-bank system proposes removing those minimum deposit requirements and instead specifying minimum percentages of reserve assets maturing within one and five working days. It suggests draft EBA liquidity standards as a possible starting point for calibrating the buckets. The paper frames this as a policy recommendation to the Commission, not as a change already made. European System of Central Banks: response to the MiCA review consultation, September 2026
The response says liquidity rules support redemption rights and weigh effects on banks, financial stability, reserve markets and issuer models. A deposit floor specifies where reserves sit; a maturity bucket focuses on when assets become cash. European System of Central Banks: response to the MiCA review consultation, September 2026
Reserve composition links redemption speed to bank funding
Bank deposits can provide immediate liquidity, but a large, concentrated issuer balance may also create a funding link between a stablecoin and the banks holding its reserves. Shorter maturity assets may diversify that exposure, yet their liquidity under stress depends on instrument quality, market depth and operational access. The proposal therefore shifts the design question rather than removing liquidity risk.
For issuers, changing the reserve mix could affect yield, custody arrangements and the ability to meet redemptions quickly. For banks, deposits linked to large token issuers may behave differently from a broad retail base. The ESCB’s response identifies these considerations; it does not quantify a market-wide effect or show that a run is currently under way. European System of Central Banks: response to the MiCA review consultation, September 2026
The central banks also maintain the prohibition on interest payments to stablecoin holders in their response and call for stronger safeguards around reserves. That position shows the paper is not simply a deregulatory proposal. It seeks a different liquidity test while retaining protections, diversification and oversight measures within the Commission’s broader MiCA review. European System of Central Banks: response to the MiCA review consultation, September 2026
The Commission must decide whether the framework should change
The Commission’s targeted consultation is a policy review step. The ESCB submission is evidence of the central-bank system’s view, not the final Commission position. Any legal change would require the next steps in EU policymaking, so issuers should not rewrite reserve policy solely because the recommendation appeared in a consultation document. European Commission: targeted consultation on the MiCA review
If maturity buckets move forward, the calibration will be central: what counts as eligible liquidity, how maturities are distributed, and how assets behave in stressed markets. Supervisors may also need to consider concentration by issuer, custodian, bank and instrument. The proposal itself points toward EBA technical standards as a starting point for analysis, not a finished operational rule. European System of Central Banks: response to the MiCA review consultation, September 2026
Readers can follow the consultation record, subsequent Commission documents and any legislative proposal to see which ideas survive. For now, the clearest summary is that current MiCA deposit floors remain the described legal baseline while the ESCB has urged a maturity-based alternative. Keeping those two states separate is essential for accurate compliance planning and market reporting.