Key facts
- The response examines third-country multi-issuer arrangements.
- Reserve location and redemption rights are central concerns.
- The documents are policy recommendations, not new legislation.
What the ESRB submitted
The European Systemic Risk Board's response to the European Commission's MiCA review is dated 29 September. An accompanying letter dated 30 September reiterates concerns about fungible stablecoins issued by entities in both the EU and third countries. The ESRB's publication catalogue lists the contribution under 30 September.
The response describes a stress scenario in which holders seek redemption from an EU issuer while some reserves are held elsewhere. Restrictions on transferring those reserves could complicate access to liquidity. It also discusses incomplete information about token holders and the allocation of liabilities across entities. These are identified vulnerabilities, not a report of a newly observed stablecoin run.
What the board is asking for
The accompanying letter points back to the ESRB's 2025 recommendation. It calls for clarification of the treatment of such schemes under MiCA, or safeguards including stronger supervision, international cooperation and legal changes.
Our interpretation is that the contribution puts reserve availability and enforceable redemption rights at the centre of the review. It does not itself amend MiCA or determine the legal status of every named stablecoin. The practical outcome depends on subsequent action by the relevant EU institutions; the consultation document alone cannot establish that an issuer has become prohibited.
Primary sources
Reporting is based on the linked primary sources. Company statements are attributed to their authors; they are not independent test results.
- ESRB — Response to the European Commission's MiCA review consultation
- ESRB — Letter accompanying the MiCA consultation contribution
- ESRB — Responses and letters catalogue
Source links checked 16 Oct 2026
Understand the background
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