Only three of the world’s 30 largest stablecoins currently comply with Europe’s MiCA rulebook, according to Circle’s EU policy chief, and the company is now formally asking Brussels to rewrite parts of the framework before it pushes European users toward offshore platforms.
By Ana Gonzalez | October 2, 2026
In a policy submission filed on Oct. 1 as part of the European Commission’s MiCA review consultation, Circle — the issuer of USDC and the euro-backed EURC — argued that the bloc’s stablecoin rules have built a regulated issuer base at home but still fail to cover most of the tokens people actually use worldwide. Patrick Hansen, Circle’s director of EU strategy and policy, put it bluntly on social media: “only 3 of the top 30 are MiCA-compliant today.” The three tokens he identified are USDC, USDG and EURC. For everyday holders, the question this review settles is simple: will the stablecoins in your wallet stay legally available in Europe, or will rules designed to protect you end up pushing that activity outside the EU’s reach?
The Hook: A Rulebook That Misses Most of the Market
MiCA, the EU’s Markets in Crypto-Assets regulation, took full effect for stablecoin rules in mid-2024. Circle says Europe has now authorized roughly 30 e-money tokens under the framework — yet Hansen’s count shows that only a fraction of the top 30 stablecoins by global usage meet the standard. Circle’s accompanying policy post compared the top 25 stablecoins by market capitalization and named the same three compliant tokens. In plain terms: Europe has plenty of licensed coins, but the heavyweights that dominate global trading volume mostly sit outside the system. That gap is exactly what the Commission’s review consultation is designed to probe.
On-Chain Evidence: Circle’s Own Track Record Under MiCA
Circle is not a disinterested party — it is the largest MiCA-authorized issuer, and its European business has grown under the rules it now wants to adjust. Its euro stablecoin EURC passed 400 million euros in circulation in August, according to Circle figures showing 402.4 million euros outstanding on Aug. 13, more than doubling over the preceding year. EURC is issued through Circle’s licensed French electronic money institution, with reserves kept separate from corporate funds and checked by monthly third-party attestations. Eligible Circle Mint customers can redeem the token one-for-one for euros. That structure is the model Circle wants to preserve and scale.
The Core Conflict: Cross-Border Issuance, Reserves and Foreign Tokens
Circle’s submission pushes three main changes, each aimed at a different pain point:
- Cross-border issuance — Circle wants MiCA to keep allowing a licensed European entity to issue a stablecoin alongside an affiliated issuer in another jurisdiction. Restricting that model, it argues, would push European users toward offshore providers with no EU protections — a warning Circle says echoes the European Commission’s own 2020 impact assessment.
- Reserve rules — Current MiCA rules require e-money token issuers to keep at least 30 percent of backing assets in commercial bank deposits, rising to 60 percent for “significant” issuers. Circle says forcing deposits into banks concentrates credit and counterparty risk, and wants the thresholds replaced with rules based on how liquid the reserves actually are. Europe’s central banks made a similar ask in a Sep. 22 consultation response, proposing liquidity requirements covering one to five days instead of fixed deposit minimums.
- Concentration limits — Circle also challenged two European Banking Authority technical standards: a 35 percent ceiling on exposure to a single sovereign issuer and a cap tying deposits at each banking counterparty to 1.5 percent of that bank’s total assets. Large issuers could be forced to juggle relationships with dozens of banks, Circle argues.
On foreign tokens, Circle proposed a formal recognition route: an issuer would stay supervised in its home jurisdiction while distributing in Europe through a locally licensed institution, combining a European Commission assessment of the foreign framework with an EBA decision on the individual issuer. Circle explicitly pointed to the U.S. GENIUS Act as a model — under Section 18 of that law, foreign stablecoin issuers must operate under a regime the Treasury deems comparable, register with the Office of the Comptroller of the Currency, hold reserves at U.S. financial institutions and accept U.S. enforcement jurisdiction.
Market Implications: What This Means for European Crypto Users
Stablecoins are the plumbing of crypto — think of them as the checking accounts of the market, used for trading, payments and parking cash between trades. If MiCA’s review tightens rules in ways that push major tokens out of regulated European venues, users could face reduced access, worse liquidity or a drift to offshore platforms beyond EU consumer protection. Conversely, if Brussels adopts Circle’s recognition route, Europeans could gain supervised access to a much wider range of globally traded stablecoins. Circle is not alone in seeking changes: the Hyperliquid Policy Center used the same MiCA review on Oct. 1 to ask for clarity on perpetual futures, arguing they should stay under MiFID II derivatives rules regardless of the blockchain they run on, and that regulators should recognize data already public on-chain instead of layering on new reporting duties.
The Verdict
The MiCA review is still at the consultation stage, so nothing changes for holders today. But the direction matters. A rulebook that only three of the top 30 stablecoins meet is either a sign the world hasn’t caught up to Europe — or that Europe hasn’t caught up to the world. Circle, unsurprisingly, argues the latter, and it has the central banks and at least one major derivatives platform nudging in the same direction on reserve and product rules. Watch the Commission’s follow-up proposals in the months ahead: they will decide whether Europe’s stablecoin market consolidates around a handful of authorized tokens or opens up to globally dominant ones under supervised conditions.
The cryptocurrency market remains highly volatile. This article is for informational purposes only and does not constitute financial advice.
only 3 of the top 30 compliant and 2 of them are circle coins lol, of course they want the rules rewritten
usdc being compliant while usdt sits out is the whole play here. circle wins either way the review lands
The offshore-flight warning gets old. EURC more than doubled to 400 million under these exact rules, so clearly the framework is workable.
400 million EURC is nice growth but usdt sits around 140 billion. that scale gap makes the whole framework feel theoretical, compliant or not
140 billion usdt vs 400 million EURC is the whole review in one comparison. brussels regulated the corner of the market nobody was using
EURC doubling off a tiny base under zero competition isnt proof the framework works, its proof of a captive niche
only 3 of the top 30 compliant and they act surprised people route to offshore venues lol. USDC, USDG and EURC are basically carrying the entire MiCA stablecoin market rn
hansen isnt wrong tho. if the other 27 tokens get pulled from EU wallets nobody switches to EURC, they just fire up a VPN. the rules solve nothing
^ the VPN point is the whole thing. regulators keep drafting rules like geography still exists on-chain
the VPN point keeps being right and keeps being ignored. every MiCA consultation drafts like custody has a passport
Circle asking Brussels to rewrite MiCA during the review consultation is quite convenient. Tighter rules on the other 27 issuers happen to protect USDC market share. Framing it as consumer protection is a smart touch.
Of course the timing is convenient for Circle, that does not make the point wrong. 27 of the top 30 sitting in EU wallets without MiCA compliance is a real problem no matter who flags it.
hansen dropping that 3 of 30 number during the review consultation is smart politics. question is whether brussels fixes the licensing cost or just adds another layer of paperwork nobody complies with