The euro area's central banks want the ban on paying stablecoin holders to reach lending, staking and loyalty points

What happened

The European System of Central Banks, meaning the European Central Bank together with the national central banks of the European Union, has published a 57-page response to the European Commission's targeted consultation on the Markets in Crypto-Assets Regulation. Its central request on stablecoins is that an existing prohibition be widened. MiCA already bars issuers of e-money tokens and crypto-asset service providers from paying interest on them; the response argues the ban "should not be limited to cases where CASPs offer services governed by MiCAR, but should apply also to unregulated services, such as crypto borrowing, lending and staking". The reasoning is that the prohibition is easy to route around. Recent developments in decentralised finance, the document says, show how stablecoins "may be transformed into yield-bearing arrangements through lending, staking or other layered structures, thereby potentially circumventing the prohibition on direct remuneration", and it concludes that "maintaining and, where necessary, strengthening the prohibition", covering "both direct and indirect forms of remuneration", "should be a clear legislative priority". It names the indirect forms it has in mind: "some kinds of benefits provided under loyalty programmes, or liquidity mining incentives embedded in DeFi arrangements". The principle underneath is stated as a point of law rather than of policy, that "electronic money is intended to be used for making payments and not as a means of saving". The response asks for the interest ban to be kept for asset-referenced tokens as well, on the ground that they "could be designed to replicate the economic profile" of an e-money token. In the key messages of the same document the central banks ask for a different rule to be taken away. MiCA requires that "at least 30% of reserve assets (60% for significant EMTs/ARTs) be held as deposits at credit institutions". The response says "minimum deposit requirements for ARTs and EMTs should be removed and replaced by a MiCAR requirement specifying minimum percentages of assets maturing within one and five working days (liquidity buckets)", calibrated at least on the European Banking Authority's draft technical standards, which it reports as requiring a daily bucket of 40 per cent for significant stablecoins and 20 per cent for others and a weekly bucket of 60 and 30 per cent. The reason given is not relief for issuers. It is that large-scale stablecoin adoption may leave banks with a funding structure "both less stable and more costly", with consequences for their ability to supply credit.

Why it matters

Read together, the two requests are a statement about what a stablecoin is for. The tightening says a token that references a currency must not become a savings instrument by any route, including routes that sit outside the regulation entirely, which is a considerable extension of a financial regulator's reach: crypto lending and staking are named precisely because they are unregulated services, and the request is that a MiCA prohibition follow the economic effect into them. The loosening says the reserve behind that token should be held for liquidity rather than parked in banks. Both follow from the same premise, that these instruments are payment instruments, and each is uncomfortable for a different constituency. The deposit floor is the more surprising of the two, because it is a central bank asking that a requirement to keep money in banks be dropped. The floor was written to tie a token's reserve to the banking system; the response argues the tie now runs the wrong way, since an issuer facing heavy redemptions would have to pull a large deposit out of a bank over a short period, and a bank funded that way is funded less stably than one funded by depositors. That is the mirror image of the argument usually made for the rule, and it is made by the institution with the least interest in issuers' convenience. For the market the practical question is where remuneration goes if it cannot reach the holder. Nothing in the response addresses payments between an issuer and a distributor calculated on balances, which is the arrangement Circle and Binance signed this month and which pays an intermediary rather than a holder. A prohibition drawn around the holder leaves the competition for balances intact one level up.

What is not settled

The document's date cannot be pinned to a day. Its cover gives "September 2026" and no more; the file was made on 15 September on its own internal timestamp; no ECB index page listing it was found on the press or publications indexes, and the consultation-response directory listing returns 403. It is filed here under 22 September, the day it was first reported and the day this desk could evidence it was public, and that is a date of publicity rather than of publication. What the Commission will do with any of it is unknown. This is a consultation response and not a proposal: nothing here changes a rule, and the review it feeds into has no published timetable in the document. The response is also explicit that several of its own asks need more work, describing the liquidity bucket calibration as "subject to further analysis" and the change to the deposit requirement as subject to "sound calibration to take into account potential second-order effects". How a prohibition on unregulated services would be enforced is not set out. The response asks that the ban apply to crypto borrowing, lending and staking without saying which supervisor would apply it, to whom, or how an arrangement offered from outside the Union would be caught, and the loyalty-programme example raises the question of where a marketing benefit ends and remuneration begins.