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【Circle: Recommends that the EU MiCA Retain a multi-issuer structure】

Circle disclosed that it has submitted a response to the European Commission’s targeted consultation on MiCA. Circle said that MiCA has given Europe a first-mover advantage, with approximately 30 e-money tokens currently authorized, but among the top 25 stablecoins by global market capitalization, only 3 are subject to MiCA regulation, namely USDC、USDG and EURC. The gap is that the MiCA regulatory scope does not cover the largest global tokens. Circle recommends retaining a multi-issuer structure, under which globally circulating stablecoins would be jointly issued by MiCA authorized EU entities and foreign regulated entities. It also recommends establishing equivalence and recognition arrangements similar to EMIR、CSDR and MiFIR for foreign-regulated stablecoins, with the regulators in the jurisdictions where the issuers are based primarily responsible for supervision, and EU-level equivalence determinations and recognition of EBA entities. Regarding reserve requirements, Circle believes that MiCA requiring issuers to deposit at least 30%of reserve assets with commercial banks would increase bank credit and counterparty risks. It supports the European Central Bank reconsidering this requirement and recommends removing the two concentration rules in the EBA technical standards.