From 12 November 2026 the European Banking Authority (EBA) will supervise the reserve, the capital, the liquidity rules and the recovery and redemption plans for USDC. An e-money token (EMT) is a stablecoin that refers to one official currency, and USDC refers to the US dollar. USDC is the first EMT classified as significant, among 45 notified in the EU. The EBA has classified it under MiCA, the Markets in Crypto-Assets Regulation, after applying that law’s tests.

What the EBA takes on 12 November

Dual supervision will start then. Four areas will move to the EBA from France’s prudential supervisor, the ACPR (“Autorité de Contrôle Prudentiel et de Résolution”).

Own funds will move. That is capital the issuer holds apart from the reserve, the assets that back USDC. The reserve will move too, along with the liquidity requirements that cover redemption requests. So will the recovery plan and the redemption plan, which deal with stress and with an orderly wind-down.

The ACPR will keep governance, qualifying holdings, fit and proper checks, outsourcing and conflicts of interest. Both authorities will coordinate the handover and keep cooperating afterwards.

Issuers of a significant asset-referenced token (ART) come under the EBA. An ART refers to a basket or to other assets. A significant EMT stays under both the EBA and the home authority. The EBA creates, runs and chairs a college for each such issuer and uses its powers with other authorities and with that college, as its MiCA role page sets out. Members cooperate and share information. They can issue opinions that do not bind, on points MiCA sets out. Extra requirements apply because of the greater risks such tokens may pose.

Who issues USDC

Circle Internet Financial Europe SAS (Circle SAS) issues USDC in the EU, and Circle Internet Financial, LLC (Circle LLC) issues it in the United States. Circle’s MiCA white paper says that from 1 July 2024 Circle SAS became a second issuer, that coins from the two issuers are interchangeable, and that backing for holders in the European Economic Area sits with Circle SAS while backing for holders outside that area sits with Circle LLC. The same document, last amended on 15 September 2026, says that on that date USDC was not a significant EMT.

According to Finance Magnates, Circle put the worldwide stock of USDC at $73.3 billion when June ended, the decision covers USDC alone, and EURC, Circle’s euro token, is issued on the same French licence.

Seven tests, three are enough

Regulation (EU) 2023/1114 gives the EBA, through Articles 43 and 56, the job of labelling ARTs and EMTs significant. Three of seven criteria are enough for an EMT. Article 56 uses the seven that Article 43 lists for ARTs. The decision does not name the criteria USDC met.

A holder count above 10 million is one test. Value issued, market value or reserve size above €5 billion is another. A third needs both a daily average above 2.5 million transactions in the relevant period and a daily average value above €500 million. Further tests cover gatekeeper status for core platform services under the Digital Markets Act, Regulation (EU) 2022/1925, international weight in the issuer’s business, including payments and remittances, a link from the token or its issuers to the financial system, and another ART or EMT from the same issuer plus a crypto-asset service.

Three criteria are quantitative, with thresholds in MiCA. Two are qualitative. Delegated Regulation (EU) 2024/1506, a Commission text, sets the indicators for that pair. Where several issuers put out the same EMT, the criteria run on the combined figures. Each year the EBA looks again at whether the significant label fits or the tests are still met.

What a holder in the EU can expect

Circle SAS has to follow MiCA on the reserve, on custody of it and on how those assets may be invested. Those rules replace the older e-money safeguarding standard. Own funds have to equal at least 3% of the average reserve, drawn from the reserve logged at the close of each calendar day over the prior six months.

Pay must not reward people for loosening risk controls. The issuer has to let different crypto-asset service providers (CASPs), firms authorised to hold crypto-assets for clients, custody USDC on fair terms. That includes firms outside Circle’s group.

The issuer has to track liquidity for redemption requests and keep a policy and procedures so the reserve can support ordinary operations and a liquidity squeeze. Stress tests will run regularly. The EBA may tighten the liquidity rules if the results call for it.

An outside audit will be required every six months from the classification decision.

USDC is a notified EMT inside MiCA. The 9 October article covers stablecoins beyond that regime. ESMA told national regulators that crypto firms authorised under MiCA should end EU-client service in those coins and run off leftover holdings within three months.

The June pact with New York

On 2 June 2026 the EBA announced a memorandum of understanding with New York’s Department of Financial Services (NYDFS) under MiCA. The pact is about closer cooperation on firms that do stablecoin business across borders.

Principles and procedures cover information sharing, coordinated supervision of stablecoins issued from New York State and of stablecoins issued in the EU, including firms the EBA supervises directly under MiCA, day-to-day help, and quick coordination in a crisis or an emergency.

Article 126 lets the EBA make administrative agreements with supervisors outside the EU to exchange information. Confidential sharing under the June pact required a finding that NYDFS secrecy rules match MiCA. The EBA found the NYDFS regime equivalent.

This article is not investment advice.