The European Commission is assessing feedback from a targeted consultation on the Markets in Crypto-Assets Regulation, known as MiCA. The consultation, opened in May 2026, sought input on how the framework is functioning and whether updates are needed as crypto markets evolve. Responses from major industry participants, including Circle and the Hyperliquid Policy Center, focus on stablecoin reserves and the treatment of on-chain perpetual futures.

MiCA, adopted in 2023, established the European Union’s primary rules for crypto-asset markets and sits alongside the second Markets in Financial Instruments Directive, or MiFID II, which governs traditional financial instruments and derivatives. The review examines areas including perpetual futures, stablecoin operations, and investor access to global liquidity.

Circle Calls for Changes to Stablecoin Reserve Rules

Circle, which describes itself as the largest MiCA-authorized e-money token issuer and issues USDC and EURC, urged the Commission to revise mandatory bank deposit requirements for stablecoin reserves. Under current MiCA rules, e-money token issuers must hold at least 30 percent of reserves in commercial bank deposits. For tokens classified as significant, the minimum rises to 60 percent.

The company argued that these fixed thresholds expose issuers to credit and counterparty risks in the banking system. Circle pointed to its experience in March 2023, when $3.3 billion of USDC reserves were held at Silicon Valley Bank at the time of the lender’s failure. The stablecoin temporarily lost its dollar peg before the funds became available after U.S. authorities protected depositors.

Circle proposed replacing the fixed deposit minimums with requirements based on the liquidity of reserve assets, focusing on how quickly those assets can be accessed for redemptions. This approach aligns with a similar proposal from the European Central Bank and the European System of Central Banks, which suggested setting minimum proportions of reserve assets that mature within one working day and five working days.

The issuer also requested the removal of two concentration limits. One imposes a 35 percent ceiling on exposure to a single sovereign asset. The other restricts deposits with any individual bank to an amount equal to 1.5 percent of that bank’s total assets. Circle stated that the sovereign limit can constrain access to government-backed liquid assets for dollar-denominated tokens, while the bank counterparty rule could require large issuers to maintain relationships with numerous banks, increasing operational complexity.

Support for Multi-Issuance and Cross-Border Recognition

Circle asked the Commission to preserve multi-issuance arrangements. Under this model, an EU-authorized entity and a foreign-regulated counterpart can jointly issue the same stablecoin, maintaining fungibility while allowing reserve rebalancing between jurisdictions. The company warned that restricting the structure could drive European users toward offshore providers operating outside MiCA protections.

For the longer term, Circle suggested an equivalence and recognition regime for foreign-regulated stablecoins. Under the proposal, home regulators would retain primary oversight, while EU-licensed institutions would handle local distribution. The process would combine a European Commission assessment of a foreign jurisdiction’s framework with a decision by the European Banking Authority on individual issuers.

Only three of the top 25 stablecoins by market value currently operate under MiCA regulation: USDC, USDG, and EURC. Circle received an Electronic Money Institution license from French regulators in July 2024, enabling its French entity to issue USDC and EURC for European customers. EURC circulation later surpassed 440 million USD after more than doubling over the prior year.

Hyperliquid Policy Center Seeks MiFID II Treatment for Perpetual Futures

The Hyperliquid Policy Center submitted its response on October 1, 2026, describing it as the group’s first policy filing outside the United States. It argued that on-chain perpetual futures should be classified according to their economic characteristics rather than the technology used for recording and settlement.

The center stated that existing ESMA guidelines already treat perpetual futures as MiFID II instruments and requested confirmation through those guidelines without the need for new legislation. It distinguished perpetual futures from contracts for difference, noting that perpetual futures trade on a central order book against other participants, whereas CFD providers typically set the price and take the opposite side of trades. As a result, the group said retail limits designed for CFDs should not automatically apply.

Hyperliquid also called for recognition that public blockchains provide verifiable records. It argued that firms should not be required to file reports on data already available on public chains for transparency and recordkeeping purposes.

Additional Industry Input and Next Steps

The Global Blockchain Business Council also responded, seeking clearer token classification rules, proportionate safeguards for stablecoins, and reduced overlap between MiCA and payment services regulations. On cross-border issuance, it called for clear redemption responsibilities, enforceable mechanisms for reserve movement between entities, and an identifiable accountable EU supervisory structure.

The Commission will review all submissions as part of its assessment of MiCA and activities that currently fall outside its scope. No decision timeline has been announced. The feedback represents proposals from market participants and does not amend the regulation.