MiCA 2.0 Floats T-Bill-Like Reserves for Euro Stablecoins

Dollar-denominated stablecoins control $310B of the $311B stablecoin market — nearly 99.7% — and Europe's MiCA 2.0 review is now confronting that hegemony head-on.

Why the ECB Softened Its Anti-Stablecoin Stance

European Central Bank officials have historically opposed dollar-pegged stablecoins, warning they could undermine monetary control in the eurozone. But the calculus is shifting. John Orchard, chairman of the Digital Monetary Institute at OMFIF, notes that individual ECB officials now “tolerate stablecoins on bank balance sheets and perhaps as a remittance tool.” The U.S. passage of the GENIUS Act — which defines payment stablecoins and tasks the Fed and OCC with oversight — forced Europe to reconsider its own posture.

Non-dollar stablecoins barely register — less than 0.5% of the total market, per DeFiLlama. That asymmetry has made reserve requirements a flashpoint.

The Reserve Requirement Debate: Bank Deposits vs. Government Debt

MiCA currently forces stablecoin issuers to park reserves back in the banking system. The GENIUS Act allows reserves in U.S. government debt. Europe lacks a unified treasury bond market, so the European Commission is “toying with the idea of reviewing the reserve requirements,” Orchard says, potentially letting stablecoin operators buy money market instruments from European governments instead.

This would be a direct copy of the U.S. T-bill model. The banking lobby on both sides of the Atlantic has fought to prevent stablecoins from paying yield, citing deposit flight risk. Orchard expects the EU Commission to revisit the issue but predicts no change. Still, the Qivalis group — a consortium of banks building a euro-denominated stablecoin — shows how bank-led issuance can satisfy internal reserve requirements while pushing back against dollar dominance.

Multi-Issuance and the Fragmentation Risk

A separate headache: how to treat multi-issuance stablecoins like Circle’s USDC, which can be minted by different legal entities across jurisdictions yet presented as a single token. Catarina Veloso, regulatory director at Notabene, says the Commission originally intended to support multi-issuance models under MiCA. But the ECB and other stakeholders pushed back during implementation. Imposing geographic limits would force Circle Europe to build a fragmented, jurisdiction-specific version of USDC. “One of stablecoin’s main value-adds is that it's not a payment system built within a specific jurisdiction,” Veloso says. “That value is diluted by the fact it’s now being captured by regulatory frameworks that do exist within borders.”

If the Commission adopts a GENIUS-style reserve model, expect euro-denominated stablecoins like Qivalis to gain traction — and a quiet but real contest over the architecture of cross-border payments.

Source: Three years after MiCA became law, Europe's crypto framework is undergoing a rethink
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