The European System of Central Banks has proposed removing MiCA’s fixed bank-deposit floors for stablecoin reserves and replacing them with minimum liquidity requirements tied to assets maturing within one and five working days.
The recommendation appears in the ESCB’s response to the European Commission’s review of the Markets in Crypto-Assets Regulation. It is a policy proposal, not an amendment already in force. Any change would require the EU legislative process, while the detailed calibration would still need further analysis.
From deposit quotas to maturity buckets
MiCA currently requires at least 30% of relevant reserve assets to be held as deposits at credit institutions, rising to 60% for significant e-money tokens and asset-referenced tokens. The ESCB argues that those predefined percentages should be removed and that Article 36(4) should instead set floors for daily and five-working-day liquidity buckets.
As a starting point, the central banks point to draft regulatory technical standards issued by the European Banking Authority in 2024. For tokens referencing official currencies, the draft calls for at least 20% of reserves for non-significant tokens and 40% for significant tokens to mature within one working day. The five-working-day thresholds are 30% and 60%, respectively.
The distinction matters operationally. A deposit quota dictates where part of the reserve must sit; a maturity bucket focuses on how quickly reserve assets can become available for redemptions. The ESCB says overnight reverse repurchase agreements and short-term sovereign bonds could provide liquidity alongside bank deposits, subject to appropriate safeguards.
Why central banks see risk in the existing link
The ESCB says mandatory deposit holdings create a direct connection between stablecoin issuers and banks. During a run, an issuer could need to withdraw a large deposit quickly to meet redemptions. If that balance represents a meaningful share of a bank’s funding, the withdrawal could create liquidity pressure at the lender.
The response also acknowledges the other side of the trade-off: sight deposits give issuers a buffer that can be drawn down without selling securities into a stressed market. That is why the proposal does not simply remove the requirement. It would substitute quantitative maturity floors and retain controls intended to address credit, market, concentration and contagion risks.
The ESCB also notes that two sets of EBA technical standards supporting MiCA’s reserve regime have not yet been approved by the Commission. According to the response, that leaves some concentration-risk and bank-creditworthiness requirements not yet enforceable. The central banks call for the standards to be implemented swiftly and suggest considering additional diversification requirements.
What payments firms should watch
For issuers, the proposal could broaden reserve-management options and reduce reliance on low-yield bank deposits, but it would not turn the reserve into an unrestricted investment portfolio. The emphasis would move toward measurable redemption capacity over short time horizons, while eligible assets would still need to satisfy risk and liquidity constraints.
For banks and payment partners, the change could reduce concentrated exposure to volatile stablecoin deposits, while increasing the role of repo markets and short-dated public debt in reserve operations. Issuers would need treasury systems capable of monitoring maturity ladders, counterparty exposures and redemption liquidity continuously rather than treating compliance as a static deposit allocation.
The Commission’s review will determine whether the proposal advances. Until legislation and implementing standards change, firms should treat the existing MiCA framework as the governing regime and the ESCB’s liquidity-bucket model as a direction for policy debate rather than a new compliance rule.