Global Digital Finance (GDF) has submitted a response to the European Commission’s targeted consultation on the review of the Markets in Crypto-Assets Regulation (MiCA). The response consolidates member input gathered through a structured questionnaire, detailed written submissions and follow-up clarifications from stablecoin issuers, crypto-asset service providers (CASPs), market infrastructure and payments firms, and professional market participants.
GDF welcomes the Commission’s early review, noting that MiCA has provided an important foundation for regulatory certainty and a more harmonised European market. The review should now focus on areas where implementation experience has revealed ambiguity, fragmentation, disproportionate burden or unintended barriers to innovation and international competitiveness. GDF supports regulation that is technology neutral, activity- and risk-based and capable of operating across borders, without mechanically applying rules designed for intermediated entities to decentralised software, non-custodial technology or tokenised forms of already-regulated assets.
On stablecoins, GDF calls for recalibrating the fixed 30% and 60% commercial-bank deposit requirements towards a diversified pool of high-quality liquid assets, including central bank deposits; more risk-sensitive own-funds and significance criteria focused on actual EU systemic relevance; and a narrower remuneration prohibition that retains the ban on issuer-paid interest while permitting payment-linked rewards. The response supports permitting multi-issuance only under a dedicated framework with strong safeguards, an outcomes-based equivalence regime for global stablecoins, and a clearer EU nexus test for euro-denominated tokens issued outside the EU, so that euro stablecoins can scale internationally.
Other priorities include clarifying the MiCA and MiFID boundary; removing duplicate licensing between MiCA and PSD3/PSR for the same EMT activity; preserving EU CASPs’ access to global liquidity; treating genuinely decentralised protocols and staking proportionately, with obligations attaching to identifiable intermediaries rather than software; confirming that tokenised deposits remain deposits; and advancing EU work on the private-law treatment of tokens, including ownership models and a predictable conflict-of-law rule.
Date:
September 2026