Key Notes
- USDC is the first of 45 e-money tokens notified in the EU to receive significant status under MiCA.
- From November 12, the EBA will supervise capital, reserves, liquidity and recovery and redemption plans for Circle’s European issuer.
- France’s ACPR will retain responsibility for governance, management suitability, outsourcing and conflicts of interest.
The European Banking Authority has classified Circle’s USDC as the European Union’s first significant e-money token under MiCA, setting up a split supervisory arrangement with France’s banking regulator from November 12.
The EBA announced the decision on October 14 after assessing USDC against the regulation’s significance criteria. USDC is the first of 45 e-money tokens notified under MiCA in the EU to receive the designation.
The decision concerns USDC issued by Circle Internet Financial Europe SAS. It builds on an existing regulated business, with responsibilities divided between the EU-level authority and France’s Autorité de contrôle prudentiel et de résolution, or ACPR.
Who Will Supervise What?
From November 12, the EBA will take over supervision of the issuer’s own funds, reserve assets, liquidity requirements, and recovery and redemption plans. ACPR will retain oversight of governance, qualifying shareholdings, management suitability, outsourcing and conflicts of interest.
These categories address different parts of a stablecoin issuer’s operations. Own funds are the issuer’s capital, while reserve assets support the tokens it issues. Liquidity concerns whether resources can meet payment obligations; recovery and redemption planning addresses how an issuer responds to stress or an orderly wind-down.
MiCA’s legal framework explicitly provides for this division of responsibilities for significant e-money tokens issued by electronic-money institutions. It also requires close cooperation between the EBA and the other authorities involved.
The practical significance is coordination: supervision of financial safeguards moves to a European authority, while oversight of how the French issuer is run remains national. Neither side’s responsibilities cover the entire business on their own.
Significant Status Is a Separate Regulatory Step
MiCA distinguishes e-money tokens, which reference a single official currency, from asset-referenced tokens. USDC falls into the former category because it references the US dollar.
The regulation’s significance assessment considers factors including the number of holders, token value, transaction activity, international use and connections with the financial system. Classification generally requires at least three of the applicable criteria to be met and is reassessed annually.
Those rules make significance a supervisory category tied to scale and activity. It is not a claim about a token’s investment merits. The EBA announcement does not identify the particular thresholds or calculations behind USDC’s classification.
For readers following MiCA, this separates two questions: whether an issuer is authorized to operate, and which authority supervises particular obligations once a token becomes significant.
Circle’s French Licence Came First
Circle received its French electronic-money institution licence from ACPR in July 2024. Its 2024 announcement described the start of USDC and EURC issuance in the EU under MiCA and the opening of Circle Mint France for business customers.
At that stage, Circle said eligible customers could mint and redeem the stablecoins through its French operation using local banking capabilities. The October designation therefore sits on top of the licensing and issuance framework established more than two years earlier.
The distinction matters because a change in supervisor and an initial authorization mark different stages of a regulated issuer’s development. The latest decision is specifically about USDC; Circle’s issuance of EURC does not mean both tokens have received significant status.
It also comes as platforms work through separate MiCA obligations. CoinScreamer previously covered ESMA’s exit guidance for non-compliant stablecoins, which concerns access to tokens through authorized service providers rather than the allocation of supervisory duties for a significant issuer.
A Cross-Border Oversight Challenge
USDC also has a US issuer, Circle Internet Financial LLC. Alongside the classification, the EBA disclosed a memorandum of understanding with New York’s Department of Financial Services to support cooperation and information sharing.
That adds a cross-border channel to the European supervisory split. The next concrete milestone is November 12, when the announced transfer of responsibilities is due to take effect.
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