Circle: Suggests that the EU MiCA retains a multi-issuance structure

Circle disclosed that it has responded to the European Commission's targeted consultation on MiCA. Circle stated that MiCA has provided a first-mover advantage for Europe, with approximately 30 types of electronic currency tokens authorized. However, among the top 25 stablecoins by global market capitalization, only 3 are regulated by MiCA, namely USDC, USDG, and EURC, indicating a gap in the regulatory scope of MiCA that fails to cover the largest global tokens.

Circle suggests maintaining a multiple issuance structure, where globally circulating stablecoins are jointly issued by EU entities authorized under MiCA and foreign regulatory entities. It also recommends establishing an equivalence and recognition system for foreign regulatory stablecoins similar to EMIR, CSDR, and MiFIR, with the regulatory authority of the issuer's jurisdiction primarily responsible for supervision, while the EU level conducts equivalence recognition and EBA entity approval. Regarding reserve requirements, Circle believes that MiCA's requirement for issuers to deposit at least 30% of reserve assets in commercial bank deposits will increase bank credit and counterparty risk, supporting the European Central Bank to reconsider this requirement, and suggests removing two concentration rules from the EBA technical standards.