What Changed
- EBA designates USDC as the first significant e-money token among 45 notified EMTs under MiCA.
- Dual supervision by EBA and ACPR takes effect on 12 November 2026 for designated prudential areas.
- EBA signs a Memorandum of Understanding with NYSDFS to enhance cross-border supervisory coordination.
Crypto-asset issuers, financial institutions, and market participants operating in the European Union face a significant regulatory development following the classification of USDC as the first significant e-money token (EMT) under the Markets in Crypto Assets Regulation (MiCA). Issued in the European Union by Circle Internet Financial Europe SAS and in the United States by Circle Internet Financial, LLC, USDC is currently the only token among the 45 EMTs notified under MiCA in the EU to be designated as significant by the European Banking Authority (EBA).
This regulatory classification establishes a dual supervision framework between European and national authorities. Starting from 12 November 2026, direct supervisory responsibilities over Circle Internet Financial Europe SAS concerning own funds, reserve of assets, liquidity requirements, and recovery and redemption plans will transfer from France's Autorité de Contrôle Prudentiel et de Résolution (ACPR) to the EBA. Meanwhile, the ACPR will maintain supervisory oversight over areas including governance, qualifying holdings, fit and proper assessments, outsourcing, and conflicts of interest.
The EBA carries out annual assessments to classify Asset-referenced tokens (ARTs) and EMTs as significant under Articles 43 and 56 of MiCA, using indicators established in Commission Delegated Regulation (EU) 2024/1506 and EBA Decision EBA/DC/558. Under Article 117 of MiCA, issuers of significant EMTs fall under dual supervision. The EBA exercises its powers in close cooperation with other competent authorities pursuant to Articles 117(5) and 128 of MiCA, as well as supervisory colleges established under Article 119 of MiCA.
To support supervision of cross-border stablecoin operations, the EBA has signed a Memorandum of Understanding with the New York State Department of Financial Services. This agreement facilitates cooperation and information exchanges between European and United States regulators supervising USDC issuers across jurisdictions.
Who May Be Affected
Circle Internet Financial Europe SAS, crypto-asset service providers, and issuers of e-money tokens operating in the European Union.
Cross-Border Context
Connects EU regulatory supervision under MiCA with state-level oversight in the United States through an MoU between the EBA and the New York State Department of Financial Services.
What to check next
- Monitor future EBA annual significance assessments for other notified EMTs and ARTs under MiCA.
- Review official text of Commission Delegated Regulation (EU) 2024/1506 and EBA Decision EBA/DC/558.
This article provides general information and does not constitute legal advice. Consult the official text and obtain advice appropriate to your circumstances where needed.