欧洲央行寻求修改由Tether在2024年提出的MiCA储备要求

The European Central Bank and European Union central banks have called for the replacement of the minimum deposit ratio of stablecoin reserves with mature-based liquidity requirements

The European Central Bank (ECB) and the national central banks of the 27 member states of the European Union have formally requested regulators to propose changes to the requirement in the Cryptocurrency Markets Regulation (MiCA) that stablecoin reserves must hold a specific proportion of bank deposits. Specifically, regulators have been proposed to replace the current minimum limits of 30% and 60% bank deposit ratios with "mature-based liquidity requirements."

Core controversy: From fixed ratio to liquidity efficiency

According to current MiCA regulations, regular stablecoin issuers are required to deposit at least 30% of their reserves in commercial bank deposits. For stablecoins classified as "significant", the proportion rose to 60%. However, in response to the European Commission's consultation on MiCA, the European Central Bank System (ESCB) pointed out that this fixed deposit ratio requirement is not reasonable.

The ESCB recommends setting a minimum proportion of reserve assets that must mature within 1 working day and 5 working days, rather than mandating a fixed share of funds to be deposited in banks. The core of this new model is to focus on how quickly issuers can access reserve assets when faced with redemption pressure, rather than how much money they retain in commercial banks.

Systemic risk transmission mechanism

The ECB said in its response: "If reserves are held in the form of bank deposits, stablecoins may change the bank's financing structure by replacing deposits from stablecoin issuers with relatively stable retail deposits. Deposits in the latter tend to be less stable and more sensitive to market conditions."

Under the current model, after the stablecoin issuer receives client funds, it will deposit the required portion into one or more commercial banks. In the event of a large-scale coin redemption wave, issuers may be forced to withdraw large amounts of deposits in a short period of time. The ESCB warned that such withdrawals could expose commercial banks to the risk of runs on stablecoins. Because deposits from token issuers are different from ordinary household savings, these funds may be quickly withdrawn when the cryptocurrency market comes under pressure or token holders seek redemption.

Although EU policymakers viewed bank deposits as an easily available source of liquidity when drafting MiCA-and an April European Central Bank study also pointed out that large stablecoin issuers could use deposits to meet redemption needs of up to 60% of supply without immediately selling sovereign bonds-the study also pointed to a second risk: Drawbacks during stablecoin runs can transmit financial stress to the entire banking system. While deposits may initially protect the bond market from forced selling, they can put significant pressure on commercial banks that hold funds.

Tether CEO issued a warning two years ago

事实上，Tether首席执行官Paolo Ardoino早在2024年8月接受《连线》杂志采访时，就已对MiCA的这一存款下限结构表示担忧。他假设了一个价值100亿欧元的稳定币案例：在60%的要求下，发行方需将60亿欧元存入银行，而这些银行可能会将大部分资金用于放贷。

Ardoino举例说明：“想象一下，客户要求赎回20亿欧元的稳定币，但银行手中只有6亿欧元现金。这时，银行和稳定币都将面临破产的局面。”他认为这种结构并不安全，不仅未能降低风险，反而可能在欧洲创造“额外的系统性风险”。他的观点主要集中在发行方可能在代币持有者要求大额赎回时，恰好失去对无保险存款的访问权限这一可能性上。

此前在2024年4月，Ardoino曾引用硅谷银行（SVB）的倒闭作为无保险存款风险的证据。当时，Circle的USDC因披露其33亿美元储备金存放在倒闭银行中，一度短暂脱钩。Ardoino写道：“无保险的现金存款并非良策。如果银行破产，无保险现金将进入破产清算程序。”他主张允许发行方将所有储备金投资于美国国债等证券，因为在银行破产的情况下，证券的所有权仍归合法所有者所有。Tether已将USDT的大部分支持资产置于美国国债中，而非采用MiCA的欧洲银行存款模式，并表示只有在框架对发行方和消费者更安全时，才会重新考虑申请MiCA授权。

监管审查带来的调整契机

ESCB的建议是通过欧盟委员会对MiCA的审查程序提交的。该审查于5月20日开始公开咨询，并于8月31日结束意见征集。欧盟委员会表示，此次审查旨在收集来自代币发行方、加密服务提供商、金融机构、科技公司、学术界、行业团体及公共当局的意见，以评估在数字资产市场和国际监管发生变化后，MiCA是否依然适用。

Feedback will be used to prepare reports that comply with MiCA Articles 140 and 142. If the European Commission decides that changes to the regulations are needed, legislative proposals may be attached. At the same time, the stablecoin reserve rule is not the only focus of the ECB. A separate document released in September also called for the current prohibition on issuers from paying interest on stablecoins to be extended to include incentives provided through connected exchanges, lending products and pledge services.

Comparison with the U.S. GENIUS Act

For U.S. token holders, this controversy provides a direct contrast to the reserve system established by the U.S. GENIUS Act. The bill was signed into law by President Donald Trump in July 2025. The U.S. framework requires issuers of stablecoins allowed to pay to maintain at least 1:1 reserves. Eligible assets include the U.S. dollar, funds from regulated or protected deposit-taking institutions, short-term U.S. Treasury-backed reverse repo agreements, and eligible money market funds.

Unlike MiCA, U.S. law does not require issuers to place a fixed proportion of reserves in commercial bank deposits. The White House describes the backing assets it approves as highly liquid assets such as U.S. dollars and short-term Treasury bonds, while the law also requires issuers to publish monthly disclosures on the composition of reserves. The Office of the Comptroller of the Currency (OCC) proposed draft implementing rules in February 2026 that would require issuers under its supervision to demonstrate that they can convert each type of reserve asset into cash, including through treasury bond sales or repurchase agreements.

此外，ESCB还涉及了通过欧盟内外关联实体发行的稳定币问题。它支持欧洲系统性风险委员会（ESRB）的观点，即当前MiCA规则不允许可互换的多发行模式，并指出未来的授权应要求采取保障措施，包括评估其他国家的监管体系是否与欧盟框架等效。