Circle has urged European policymakers to revise MiCA’s rules governing stablecoin issuance and reserve requirements after its EU policy director noted that only three of the world’s 30 largest stablecoins currently comply with the framework. The company identified USDC, USDG and EURC as the only tokens among the top 30 that meet MiCA’s criteria. Circle seeks to preserve cross-border issuance models that allow European and overseas affiliates to jointly issue stablecoins, arguing that restricting such arrangements could push European users toward unregulated offshore providers. It also proposes replacing fixed bank deposit thresholds with requirements tied to reserve liquidity and availability. In its October 1 policy submission, Circle called for changes covering cross-border issuance, reserve assets and the recognition of foreign-regulated stablecoins. The submission highlighted that while Europe has authorized roughly 30 e-money tokens, fewer of the largest globally used tokens fall within MiCA’s scope. Patrick Hansen, Circle’s director of EU strategy and policy, stated that only three of the top 30 stablecoins are compliant today. The company’s proposal draws on the U.S. GENIUS Act’s approach to recognizing foreign stablecoin issuers. Circle suggested that a European recognition process could mirror this model, requiring foreign issuers to operate under supervisory regimes deemed comparable to EU standards, register with relevant authorities and hold reserves at designated financial institutions. It also advocated for reciprocal arrangements that would allow European-issued stablecoins to circulate internationally. Separately, Circle challenged two reserve concentration limits introduced by the European Banking Authority, arguing that a 35% cap on exposure to a single sovereign issuer and a 1.5% limit on deposits per bank could hinder dollar-token issuers’ access to government-backed liquid assets and create operational complexity for large issuers. Regarding reserve composition, Circle urged regulators to reconsider rules requiring e-money token issuers to hold at least 30% of backing assets in commercial bank deposits, with a 60% threshold for significant issuers. It proposed shifting focus from fixed deposit percentages to liquidity-based requirements that better align with redemption needs. European central banks had previously echoed similar concerns in their consultation responses, favoring the removal of minimum deposit requirements while maintaining liquidity safeguards over one to five day periods. Circle also pointed to its own EURC token as evidence of growing adoption under the current framework. According to figures cited in an August 18 report, EURC’s circulation surpassed €400 million, with €402.4 million outstanding as of August 13. The token is issued through Circle’s licensed French electronic money institution, with reserves segregated from corporate funds and subject to monthly third-party attestations. Eligible users can redeem EURC directly for euros at a one-to-one rate, and the company noted its use in payments, foreign exchange, treasury operations and institutional settlement. Circle attributed part of EURC’s growth to distribution across exchanges, payment providers and institutional platforms. In addition to stablecoin policy, Circle’s submission addressed regulatory clarity for perpetual futures, urging regulators to classify such products by economic substance rather than technological implementation. It opposed applying rules designed for bilateral contracts to markets using transparent central limit order books and supported recognition of publicly available blockchain data for reporting purposes.