The European System of Central Banks (ESCB) has set out detailed recommendations for the European Commission's review of the Markets in Crypto-Assets Regulation (MiCAR). The response covers stablecoin reserve liquidity, significant issuers, third-country multi-issuer arrangements and the supervision and prudential treatment of crypto-asset service providers (CASPs).
The response is an institutional contribution to a consultation, not an amendment to MiCAR. The Commission's consultation closed on 30 September 2026. Its official page says the responses will support a report on MiCA's application and may, if warranted, be accompanied by a legislative proposal. The ESCB recommendations therefore provide a basis for policy monitoring and scenario planning, but they do not create new requirements by themselves.
Reserve liquidity rather than fixed deposit percentages
For asset-referenced tokens (ARTs) and e-money tokens (EMTs), the ESCB recommends replacing minimum deposit percentages with minimum proportions of reserve assets maturing within one and five working days. It describes these as daily and weekly liquidity buckets and says their calibration would need further analysis and safeguards.
This is a proposed direction, not an instruction to alter reserve composition now. Issuers can nevertheless use it as a scenario: if future rules emphasised short-maturity liquidity, how would treasury operations, concentration, custody arrangements and redemption capacity respond?
Issuance models and significant stablecoins
The ESCB supports retaining direct EMT issuance by credit institutions as well as issuance through electronic-money institution subsidiaries. It suggests that banking supervisors could have discretion to require a separate subsidiary in particular circumstances, including some third-country multi-issuer arrangements, rather than making that structure mandatory in every case.
For non-bank issuers of significant ARTs and EMTs, the response also calls for stronger crisis-management arrangements. It recommends closer coordination between MiCAR recovery obligations and bank recovery and resolution rules, together with a tailored regime for these issuers. Firms should treat this as a policy signal for monitoring recovery planning, redemption arrangements and legal-entity dependencies, not as an operative resolution framework.
Third-country multi-issuer arrangements
The ESCB argues that MiCAR needs legislative clarification for stablecoin arrangements involving issuers inside and outside the EU. It identifies questions around equivalent third-country regimes, supervisory cooperation, reserve location and transferability, redemption rights, custody, reporting, crisis management and regulatory arbitrage.
The response does not by itself decide whether a particular arrangement is permitted. That depends on current law, the structure's facts and any subsequent legislative development. Firms with cross-border issuance or reserve models should therefore separate present legal analysis from forward-looking scenario work.
A stronger framework for CASPs
For CASPs, the ESCB supports stronger and more coordinated supervisory and prudential arrangements. Its recommendations include an enhanced role for the European Securities and Markets Authority and the Anti-Money Laundering Authority, risk-sensitive own-funds requirements, additional requirements for significant CASPs and broader indicators for identifying significance.
The response also proposes an EU intermediate parent undertaking for significant CASPs and greater group-level visibility over exposures, operational dependencies and governance. These proposals do not transfer supervisory authority or create new capital requirements by themselves. They show the scale, group-structure and cross-border information that larger CASPs may need to keep visible as the review develops.
Who should monitor the review
The policy implications are most direct for EU ART and EMT issuers, significant issuers, CASPs and complex groups containing those activities. Banks, payment institutions and electronic-money institutions may also be affected through issuance models, reserve relationships, payment-services interactions or group structures, but applicability depends on each entity's actual role and permissions.
A proportionate review can start by mapping which MiCAR role each entity performs; where issuance, reserve, custody and redemption responsibilities sit; which third-country dependencies exist; and which management information explains group-wide exposures. Those questions help firms prepare for possible change without presenting an ESCB preference as settled law.
What remains unchanged and uncertain
The ESCB response was approved by the ECB Governing Council on 7 September 2026 and published by the ECB on 22 September 2026. The Commission consultation is now closed, but the Commission's eventual report, any legislative proposal, the positions of the co-legislators and all implementation dates remain unknown.
Current MiCAR obligations and applicable technical standards must be checked separately before controls are changed. This article is general regulatory and operational commentary, not legal advice; classification, cross-border structure and firm-specific applicability may require appropriately qualified EU or local legal advice.