European central banks are recommending a significant change to how MiCA regulates stablecoin reserves, proposing that fixed requirements for deposits at commercial banks be replaced by liquidity requirements based on how quickly reserve assets mature. The European System of Central Banks wants MiCA to move from prescribed bank-deposit ratios toward a maturity-based liquidity framework, although the recommendation has not yet changed EU law.
In its response to the European Commission’s MiCA review, the ESCB said the current requirement for at least 30% of reserve assets to be held as bank deposits, rising to 60% for significant e-money tokens and asset-referenced tokens, should be removed. The central banks instead propose minimum shares of reserves that can mature within one and five working days.
Liquidity Buckets Could Replace Deposit Floors
The ESCB points to draft European Banking Authority standards as a possible starting point. Those rules envisage a daily liquidity bucket of at least 20% for non-significant stablecoins and 40% for significant ones, while the five-working-day bucket, which includes the daily portion, would rise to 30% and 60%, respectively. The percentages would therefore measure near-term asset availability rather than dictate how much of the reserve must sit at banks.
The rationale is partly financial-stability related. The ESCB argues that mandatory bank deposits create a direct connection between stablecoin issuers and credit institutions: during a redemption run, an issuer could suddenly withdraw large deposits, potentially creating liquidity pressure at the receiving bank. Highly liquid alternatives such as overnight reverse repos or short-term sovereign debt could provide redemption capacity without concentrating the same funding exposure inside banks.
That distinction matters as MiCA increasingly determines which stablecoins can circulate through regulated European platforms. Recent examples include Revolut restricting USDT under MiCA requirements while separately launching its EURR stablecoin under the EU framework. Reserve composition is therefore becoming part of stablecoin product design, distribution and bank-risk management, not simply a back-office compliance calculation.
The ESCB is not proposing unlimited discretion for issuers. Assets outside the short-term liquidity buckets would still need to satisfy MiCA requirements for highly liquid instruments with minimal market, credit and concentration risk, while additional maturity and counterparty-diversification limits could also apply. The proposed framework would change the mechanism for controlling liquidity risk rather than eliminate reserve safeguards.
ESCB Also Targets Cross-Border Enforcement Gaps
The consultation response also raises a separate enforcement problem. The ESCB says crypto-assets and stablecoin-like arrangements that do not comply with EU requirements can remain accessible to European customers through third-country providers, complicating consistent enforcement across a borderless digital market. The central banks argue that stronger EU-level supervision and enforcement are needed alongside any changes to reserve requirements.
That concern intersects with the broader licensing structure emerging under MiCA. Firms including Ripple have pursued European authorization pathways designed to support MiCA passporting, while the ESCB has backed a larger supervisory role for ESMA over crypto-asset service providers. The regulatory debate is consequently shifting from simply defining the rules to determining how consistently they can be applied across firms and jurisdictions.
The next concrete milestone is the European Commission’s treatment of the consultation recommendations. Until MiCA is formally amended, the existing 30% and 60% bank-deposit requirements remain the relevant statutory framework, while the ESCB proposal establishes a detailed alternative centered on one-day and five-day liquidity capacity, reserve diversification and stress resilience.