On September 22, 2026, the European System of Central Banks published its response to the European Commission’s review of MiCA. The core of the 61-page opinion concerns anyone holding a euro or dollar stablecoin directly: the central banks consider the obligation to park a fixed share of reserves as a bank deposit a design flaw, and propose replacing it with liquidity requirements.
One point up front, so the context is right. No rule changes on September 30. That date merely marks the end of the window in which the Commission accepts responses to the MiCA review. What you can check on your own stablecoin today is already settled, and that is what this article is about.
What the ESCB submitted to the MiCA review
The European System of Central Banks, or ESCB, is the network formed by the European Central Bank and the national central banks of the EU, which in Germany means the Bundesbank. Its contribution to the consultation is a technical opinion rather than legislation: the ESCB sets out what it regards as problematic in the current wording of the regulation, and it names alternatives.
We downloaded the document ourselves and read it in full. It sits as a PDF on the ECB’s website....
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