Europe’s top banking supervisor is pressing Brussels to widen the scope of its landmark crypto rulebook, arguing that lending activities and certain services tied to decentralized finance have outgrown the current framework and now pose risks to consumers that regulators cannot properly monitor.
The European Banking Authority (EBA) published its formal response to the European Commission’s targeted consultation on reviewing the Markets in Crypto-Assets Regulation (MiCA) on September 24, 2026. The submission does not change existing law, but it lays out a clear set of priorities for the next phase of EU crypto policy: third-country multi-issuer stablecoin schemes, crypto-asset classification standards, and oversight of crypto lending, including services that route users into DeFi protocols.
MiCA has been in full effect since December 30, 2024, with rules for asset-referenced tokens (ARTs) and electronic money tokens (EMTs) applying since June 30 of that year. Yet the EBA argues the sector is moving faster than the regulation can keep up.
The watchdog’s most concrete recommendation concerns crypto-asset lending, an activity that currently falls entirely outside MiCA’s perimeter. The EBA wants the Commission to consider bringing it under regulatory oversight, specifically covering cases where crypto-asset service providers connect customers to decentralized lending protocols.
The authority frames the issue as one of consumer protection. As more people access lending through intermediaries that channel funds into DeFi protocols, the risks to everyday users accumulate without any supervisory framework in place. Borrowers and lenders in these arrangements, the EBA contends, receive little of the disclosure and safeguards that apply elsewhere in the financial market.
Multi-Issuer Stablecoins Draw Scrutiny
On stablecoins, the EBA’s message is more nuanced. The existing requirements governing ART and EMT issuers under MiCA are broadly appropriate, the authority said, and do not need a fundamental overhaul. The concern lies elsewhere: stablecoin schemes operated by multiple issuers based outside the EU.
The EBA views these third-country multi-issuer arrangements as carrying significant to very significant risk, largely because oversight becomes harder to coordinate across jurisdictions. It is recommending that the Commission consider regulatory changes that specifically target these cross-border structures.
Part of that review would involve revisiting reserve asset requirements, particularly how much of an issuer’s reserves must be held as bank deposits, while preserving the sound risk management practices already embedded in MiCA.
The recommendations arrive as the bloc’s stablecoin rules face broader scrutiny. The European Central Bank has already pushed to widen the stablecoin yield ban, and market data underscores the gap between regulation and reality.
As of September 1, 2026, only 39 EMTs had been issued under MiCA, while no ARTs had been authorized at all. The figures reflect the EBA’s own reference date and are not a live count, but the divergence is striking: the market has gravitated toward simpler, single-currency-linked tokens, while more complex asset-backed structures have yet to clear the regulatory bar. Only three of the top fifty stablecoins by market value meet EU rules.
CategoryStatus as of Sept. 1, 2026What It CoversElectronic Money Tokens (EMTs)39 issuedCrypto-assets referencing the value of one official currencyAsset-Referenced Tokens (ARTs)0 authorisedCrypto-assets referencing other assets or asset combinations
Note: Figures reflect the EBA’s reference date of September 1, 2026, and are not a real-time count.
Classification Confusion
A recurring theme in the EBA’s response is that classifying crypto-assets under MiCA remains genuinely difficult, both for firms and their supervisors. When a token’s category is unclear, companies face delays and added costs before they can bring products to market, which works against innovation and weakens the EU’s competitive position globally.
Much of the confusion stems from blurry boundaries between MiCA and other financial services laws, including the Markets in Financial Instruments Directive (MiFID) and the Capital Requirements Directive (CRD). The EBA is urging the Commission to clarify MiCA’s scope and definitions so that businesses and regulators operate from the same playbook.
The authority is also pushing for a review of the reporting framework that applies to issuers and crypto-asset service providers. Better reporting, it argues, would give supervisors sharper tools for monitoring risk as the market evolves. The response also touches on related areas, including how multi-function crypto groups should be treated, interactions between MiCA and the PSD2/PSD3/R payment services rules, and the treatment of tokenised deposits.
What Comes Next
The EBA’s submission gives the Commission a clear set of priorities without dictating final outcomes. Multi-issuer stablecoins, asset classification, and crypto lending — particularly DeFi-linked lending — now sit at the center of the review conversation.
Whether or how these recommendations become binding rules will depend on the Commission’s next steps, but the direction of travel suggests the EU’s crypto framework is far from finished evolving. The EBA said it will continue supporting the Commission’s review with the aim of building a robust, future-proof framework for the EU crypto-asset sector.