Why Europe’s central banks want to change stablecoin reserve rules

A stablecoin reserve can look reassuring because it contains bank deposits. But the same deposit is also funding for a bank. When many token holders want their money back together, that connection matters.

In its response to the MiCA review, published on 22 September 2026, the European System of Central Banks proposes replacing minimum bank-deposit requirements for asset-referenced and e-money tokens with requirements based on reserve-asset maturities. This is a policy recommendation, not an enacted change.

What the deposit rule is trying to do

MiCA is the EU's regulatory framework for crypto-assets within its scope. E-money tokens reference one official currency. The issuer's legal structure matters when examining their backing.

The ECB's April 2026 analysis of euro stablecoins, particularly Box A, describes a 30% bank-deposit minimum for electronic money institutions issuing these tokens, with a 60% threshold in the significant-token framework. It distinguishes that model from direct issuance by a bank, which uses its balance sheet. Those percentages should not be presented as a universal rule for every stablecoin worldwide.

The deposit buffer can reduce the need to sell other reserve assets immediately during heavy redemptions. The ECB's analysis also identifies the opposite channel: withdrawals from those deposits can transmit stress to the banking system. A reserve instrument can help one institution meet withdrawals while creating funding pressure elsewhere.

A hypothetical redemption chain

Consider an issuer whose holders request redemption at the same time. To pay them, the issuer draws on deposits held at its banking partners. Those banks now face withdrawals from the issuer, even if the original loss of confidence concerned the token rather than the banks.

This illustrates a connection, not a predicted bank run. The outcome depends on withdrawal size, bank liquidity and the issuer's other assets.

The useful question is therefore not just whether reserves exist. It is whether the arrangement can turn them into payments when many people ask at once. Our stablecoin reserves and redemption guide separates that process from selling a token on an exchange.

What the central banks propose instead

The ESCB recommends minimum shares of assets maturing within one and five working days. It points to draft European Banking Authority standards as a minimum starting point for further analysis and also calls for consideration of additional diversification requirements.

Our reading is that the proposed test puts more emphasis on when liquidity becomes available, alongside where reserves are held. That would still leave practical questions about counterparties, concentration and access to payment services.

Maturity is not the same thing as a completed redemption. An asset can become payable before the holder receives funds. A useful reserve disclosure connects the investment timetable to the issuer's actual processing arrangements.

Three questions to put beside a reserve report

This worksheet is an editorial reading aid, not a regulatory compliance test or an issuer ranking.

Write down missing information as unknown. Do not substitute a large reserve total for a timetable, or a familiar bank name for an explanation of concentration. These are questions to investigate, not grounds for declaring that a particular token is safe or unsafe.

What happens next

The European Commission's targeted consultation is scheduled to close on 30 September 2026. The Commission says the responses will inform its review report and that a legislative proposal may follow if warranted. The consultation deadline is not an effective date for revised reserve rules.

For readers, the next useful evidence is a concrete legislative or technical text explaining the requirements, who they cover and when they apply. The distinction between a proposal and an operative permission is also central to our guide to crypto regulatory claims.

This analysis reflects primary documents checked on 22 September 2026. It examines one reserve-policy proposal; it does not assess individual issuers or every part of the MiCA review.