
Since 12 November, the USDC issued by Circle in the European Union has been subject to the dual supervision that MiCA provides for significant e-money tokens. The EBA takes charge of reserves, liquidity and redemption plans, while France’s ACPR retains oversight of the entity’s governance.
The European Banking Authority (EBA) now supervises, together with France’s Autorité de Contrôle Prudentiel et de Résolution (ACPR), the USDC that Circle Internet Financial Europe SAS issues in the European Union. The change is provided for in the Markets in Crypto-Assets Regulation (MiCA) for significant e-money tokens and has applied since 12 November 2026.
The EBA announced the classification on 14 October. At the time, it put the number of e-money tokens notified under MiCA in the Union at 45, and USDC is the first to be declared significant.
What a “significant” token is
MiCA reserves this category for stablecoins that reference a single official currency, such as USDC with the dollar. Article 56 tasks the EBA with classifying a token as significant when it meets at least three of the criteria in Article 43(1). These include having more than 10 million holders; a value, market capitalisation or reserve exceeding €5 billion; a daily average of more than 2.5 million transactions and €500 million; international relevance in its use, including for payments and remittances; and its interconnectedness with the financial system.
The EBA has not specified which thresholds USDC has exceeded. The indicators are set out in Delegated Regulation (EU) 2024/1506, and the authority reviews each year whether the token still meets the criteria. Circle obtained its electronic money institution licence from the ACPR on 1 July 2024 and issues USDC and EURC in the Union through its French subsidiary. In the United States, USDC is issued by Circle Internet Financial, LLC.
What changes for Circle
Since 12 November, supervision has been dual. The EBA assumes direct responsibility for the issuer’s own funds, the reserve of assets, liquidity requirements and recovery and redemption plans, which until now fell to the ACPR. The French supervisor remains in charge of corporate governance, qualifying holdings, fit-and-proper assessments, outsourcing and conflicts of interest. According to the EBA, both authorities will work together to ensure an orderly transition.
Article 58 of MiCA also imposes several obligations on the issuer. It must hold own funds equal to at least 3% of the average amount of the reserve of assets, have a liquidity policy and periodic stress tests, on the basis of which the EBA may tighten requirements, and undergo an independent audit of the reserve every six months from the date of classification. It also needs a remuneration policy that does not encourage relaxed risk management, and the token must be able to be held in custody by different authorised providers, including some outside its group.
Circle has not issued a specific statement on the decision. In a subsequent events note in its quarterly report for the period ended 30 September 2026, it states that its French subsidiary may become subject to higher capital, reserve and liquidity requirements, and that it is assessing the impact. For the cross-border activity of stablecoins, the EBA has signed a memorandum of understanding with the New York State Department of Financial Services (NYDFS).
What it means for users and what happens with EURC
The EBA has not announced any changes to the token’s terms for those who hold or use it. What takes effect is the division of supervision: a European authority now directly oversees the issuer’s capital, reserves, liquidity and redemption plans, while the French regulator continues to handle how the company is governed.
The EBA has not classified EURC, Circle’s euro stablecoin, nor did it mention other tokens in its announcement. Of the 45 tokens notified at the time, only USDC has received the significant label. According to the EURC white paper notified by Circle, last amended on 24 December 2025, EURC was not a significant e-money token as of that date.
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