EBA classifies USDC as the EU's first significant e-money token
The EBA classifies USDC as the EU's first significant e-money token. From 12 November 2026 it supervises own funds, reserves, liquidity and redemption plans. The ACPR keeps governance.
First significant e-money token
The European Banking Authority (EBA) classified USDC on 14 October 2026 as a significant e-money token. The issuer in the European Union is Circle Internet Financial Europe SAS. Of the 45 e-money tokens notified under the Markets in Crypto-Assets Regulation (MiCA), USDC is the first to receive this classification.
From 12 November 2026, USDC comes under the dual supervision MiCA sets for significant e-money tokens.
Who supervises what from 12 November
From that date the EBA supervises own funds, the reserve of assets, liquidity requirements, and recovery and redemption plans. Until then they remain with the Autorité de Contrôle Prudentiel et de Résolution (ACPR).
After that date the ACPR keeps governance, qualifying holdings, the fit and proper assessment, outsourcing, and conflicts of interest. The EBA and the ACPR will work on the transition together.
Article 56(6) of MiCA moves the relevant supervision within 20 working days of notification of the decision. The EBA sets 12 November 2026 as the start.
Circle Internet Financial Europe SAS issues the token in the EU. Circle Internet Financial, LLC issues it in the United States. The EBA has signed an agreement with the New York State Department of Financial Services for cross-border supervision. The EBA calls it a memorandum of understanding. It is meant to support cooperation and the exchange of information.
What the classification does under MiCA
The classification rests on Articles 43 and 56 of MiCA, Regulation (EU) 2023/1114. Article 56 uses the seven criteria in Article 43(1). At least three of them have to be met, either in the first reporting period or across at least two consecutive reports.
The criteria are:
- more than 10 million holders
- an issued value, a market capitalisation, or a reserve above EUR 5 billion
- a daily average of more than 2.5 million transactions and a volume above EUR 500 million
- the issuer is a gatekeeper under Regulation (EU) 2022/1925
- international scale, including use of the token for payments and remittances
- interconnectedness of the token or its issuers with the financial system
- the same issuer issues at least one other asset-referenced token or e-money token and provides at least one crypto-asset service
The EBA writes that it assessed the criteria in the regulation. The release does not say which of them USDC meets.
Commission Delegated Regulation (EU) 2024/1506, the EBA says, sets the indicators for that assessment. The EBA also points to its decision EBA/DC/558. The home authority reports the underlying data to the EBA at least twice a year. For USDC that authority is the ACPR. Once a year the EBA reassesses whether the classification still holds.
Under Article 117(4), the EBA supervises a significant e-money token issuer’s compliance with Articles 55 and 58. Recovery and redemption plans sit in Article 55. The release places significant asset-referenced tokens under EBA supervision. For e-money tokens the remaining supervision stays with the national authority.
Article 58 applies to electronic money institutions that issue a significant e-money token. Articles 36, 37 and 38, and Article 45(1) to (4), take the place of Article 7 of Directive 2009/110/EC. Article 36 requires a reserve of assets. The issuer has to keep it legally and operationally separate from its own estate. Article 45(3) and (4) require a liquidity policy and regular liquidity stress tests.
Article 45(5) sets the own-funds rate at 3 percent of the average reserve. Article 35(2), (3) and (5), together with that rate, take the place of Article 5 of the same directive. Article 35(1)(b) sets the same line at 2 percent for asset-referenced tokens.
An independent audit of the reserve is due every six months. The clock starts at the classification decision.
USDC on Solana, ESMA, and France
Circle’s white paper describes USDC as an e-money token and lists Solana among the networks. The EBA release is about the issuer.
On 8 October, ESMA published supervisory expectations for non-compliant asset-referenced tokens and e-money tokens. The expectations are written for that group of tokens. The opinion leaves the EBA’s supervision of issuers untouched. The 14 October classification concerns a notified e-money token. The write-up is ESMA: authorised firms should stop services for non-compliant stablecoins.
The French National Assembly has amendments in the 2027 budget. A swap that ends in an e-money token would drop out of the tax deferral from 2027. USDC is a token under Article 3(1)(7) of MiCA. None of the amendments is statute. The EBA classification does not change those texts. They are covered in France wants to tax stablecoin swaps and report large wallets.
What to watch
- Which of the seven criteria the EBA found met for USDC
- How the ACPR and the EBA carry out the handover by 12 November
- Whether the annual reassessment keeps the classification
- Whether further tokens among the 45 notified e-money tokens follow. The release deals with USDC
Sources
- EBA — Press release, 14 October 2026
- MiCA, ESMA Interactive Single Rulebook — Article 35 · Article 36 · Article 43 · Article 45 · Article 55 · Article 56 · Article 58 · Article 117
- EUR-Lex — Commission Delegated Regulation (EU) 2024/1506 · Regulation (EU) 2023/1114 · Directive 2009/110/EC
- Circle — USDC white paper
- SOLANA·HUB: ESMA opinion on non-compliant stablecoins · French budget amendments