Europe Can Count Its Stablecoins, Finding the Holders Is Harder

On September 1, the European Banking Authority took stock of Europe's stablecoin regime. Thirty-nine e-money tokens had been issued under the Markets in Crypto-Assets Regulation (MiCA) since its stablecoin rules took effect in June 2024. E-money tokens are the EU's legal category for stablecoins tied to a single currency. Electronic money institutions issued 36 of the 39. No asset-referenced token had been authorized.

On September 24, the EBA published that count in its response to the European Commission's review of MiCA. A day later, it released its risk dashboard for the second quarter of 2026.

Read together, the two documents show a gap. The dashboard tracks EU banks through 20 risk indicators built from supervisory reporting data. It can tell you the sector's liquidity coverage ratio stood at 158.5% at the end of June. The MiCA response describes a stablecoin market where supervisors can count the instruments but can only partly say where they are held.

If your treasury holds these instruments, that gap is the part of the filing that affects you.

The EBA's concerns sit at the edges

The EBA's main finding is that the rules for issuers mostly work. It recommended leaving most of MiCA's requirements unchanged until supervisors have more experience applying them. Its concerns sit in two places.

The first is third-country multi-issuer schemes, where an EU entity and a non-EU entity issue the same stablecoin. Two EU e-money institutions take part in such schemes today, both for dollar stablecoins. The EBA rated every risk it listed for these schemes as significant, including the difficulty of measuring how much of a stablecoin is held in the EU.

The mechanics explain the rating. The reserves behind a multi-issuer stablecoin can sit in more than one jurisdiction. In a stress event, holders can route redemptions to whichever issuer offers the better terms. If they choose the EU issuer, the reserves held in the EU may not cover what gets presented. The EBA also warned that moving reserves across borders during stress may be delayed or restricted.

The second is reserve composition. MiCA requires e-money institutions to hold at least 30% of reserves as bank deposits, rising to 60% for significant e-money tokens. The EBA said daily and weekly liquidity buckets may be more risk-sensitive than fixed percentages, provided the other reserve assets stay highly liquid.

Supervisors can only partly see who holds what

The Commission's consultation notes that MiCA requires reserves for stablecoins held in the EU to be held in the EU. MiCA never defines what "held in the EU" means. Asked whether EU holdings can be measured with enough accuracy and frequency, the EBA answered partially, citing delays and estimation challenges.

The reporting behind that answer is thin. MiCA gave the EBA no comprehensive mandate to set reporting rules for issuers and for crypto-asset service providers, the exchanges and custodians that distribute and hold these instruments. The EBA filled part of the gap with its own guidelines. It still can't place requirements directly on service providers, so issuers collect much of the data they need through private contracts. The EBA also noted that the transaction record makes it very difficult to tell where a transfer happened or whether it was a payment.

Effective supervision, the EBA wrote, "cannot rely on fragmented information, ad hoc data requests or rough market estimates."

Speed makes the problem harder. The EBA described service providers operating across borders that can reassign holdings from one of their entities to another, turning them into EU holdings almost instantly. Periodic reporting templates can't follow that. As treasury teams hand payment and liquidity decisions to software agents, holdings are likely to move more often and on shorter notice. The records supervisors rely on will fall further behind unless those records move at the same speed as the money.

"At any time" has no deadline

MiCA gives every e-money token holder a permanent right to redeem at par, at any time. It doesn't say how fast. The EBA found redemption practice running from one to four days after a request. It asked the Commission to set a maximum for normal conditions.

Some reserve assets are slower still. The EBA noted that withdrawals from money market funds can take more than four days to process, even in normal conditions. A treasury that assumes same-day liquidity is relying on something the rulebook doesn't yet guarantee.

The EBA argued that a defined redemption window would sharpen the liquidity rules too. Supervisors could test reserves against a real deadline instead of an open-ended promise.

Banks are heading toward the same question

Banks are planning instruments of their own. In the EBA's spring 2026 risk assessment questionnaire, 26% of responding banks said they expect to deploy tokenized deposits within three years, up from 16% in 2024. Their planned uses include domestic and cross-border settlement, corporate treasury management and trade finance. Some banks already issue e-money tokens. Three banks do so directly and a fourth through a subsidiary, according to the EBA.

Tokenized deposits sit outside MiCA, under banking rules. The EBA says supervisors have to look behind the label to decide what an instrument represents. EU banking rules still have no harmonized definition of a deposit. The EBA plans to report on how tokenized deposits should be classified in the fourth quarter of 2026.

Whichever form the instrument takes, the institution behind it has to show who holds it and on what terms, as fast as it moves. W3.io builds agent-powered financial workflows that enterprises can deploy in a day, not months, with business leaders staying in control.

The Commission now decides what supervisors can see

The EBA wants a legal definition of an EU holder and a reporting mandate that reaches service providers as well as issuers. It also wants a maximum redemption timeframe. Separately, the EBA is running its first significance assessment under MiCA this year, which will be the first real test of the criteria that decide when a stablecoin counts as significant.

The Commission opened the review in May. Its answers on holder definitions, reporting and redemption timing will decide whether Europe's supervisors keep working from estimates. The EBA has said what it needs. The Commission has not yet said what it will do with them.