EBA Calls on EU to Bring Crypto Lending Under MiCA in Regulatory Review
Key Takeaways
- •The EBA urged the European Commission to consider bringing crypto-asset lending, including service providers giving customers access to decentralised lending protocols, within MiCA's scope as a consumer-protection measure.
- •The EBA assessed third-country multi-issuer stablecoin arrangements, in which a single token is issued by several entities across jurisdictions outside the EU, as posing significant to very significant risk and recommended regulatory changes to contain them.
- •The authority proposed reviewing stablecoin reserve requirements, particularly the minimum reserves issuers must hold as bank deposits, while judging the existing rules for asset-referenced tokens and e-money tokens to be broadly appropriate.
- •The EBA said inconsistent crypto-asset classification under MiCA is causing avoidable costs and delays and asked the Commission to clarify where MiCA ends and frameworks such as MiFID and the Capital Requirements Directive begin.
- •As of September 1, only 39 e-money tokens had been issued under MiCA with no asset-referenced tokens authorised, and only three of the top fifty stablecoins meet EU rules.

The European Banking Authority (EBA) has urged Brussels to tighten the EU's crypto rulebook, publishing its response to the European Commission's targeted consultation on the review of the Markets in Crypto-Assets Regulation (MiCA) on September 24. Although MiCA has in full effect since December 30, 2024, the regulator contends that the sector is evolving too quickly for the framework to stand still, identifying lending, stablecoins, asset classification, and reporting as priority areas that need work.
Crypto Lending and DeFi Fall Within Scope
The EBA's most concrete request is for the Commission to consider regulating crypto-asset lending, including cases in which crypto-asset service providers give customers access to decentralised lending protocols. The authority frames the move as a consumer-protection measure, warning that lending risks currently sit outside the perimeter MiCA was designed to cover and that borrowers and lenders lack much of the disclosure and the safeguards applied elsewhere in the market.
Multi-Issuer Stablecoins and Reserve Rules
On stablecoins, the EBA flags third-country multi-issuer schemes, arrangements in which a single token is issued by several entities across jurisdictions outside the EU, as a source of significant to very significant risk and recommends regulatory changes to contain them. It also wants a fresh look at reserve requirements — in particular the minimum amount of reserves issuers must hold as bank deposits — while preserving effective risk management. At the same time, the authority judged that the existing requirements for asset-referenced tokens (ARTs), which maintain their value by referencing other assets or a basket of them, and e-money tokens (EMTs), which are pegged to a single official currency, are broadly appropriate.
Classification and Reporting
According to the EBA, inconsistent classification of crypto-assets under MiCA is causing avoidable costs and delays for firms, impeding innovation, and undermining the competitiveness of the EU market. It therefore urges the Commission to clarify the scope and definitions of the regulation, including where MiCA ends and other financial rules — such as MiFID, the EU's framework for securities markets, and the Capital Requirements Directive, which sets prudential requirements for banks — begin. The authority also recommends reviewing the reporting framework for issuers and service providers so that supervisors can monitor risk more effectively.
What Comes Next
The response lands as the bloc's stablecoin rules come under broader review. The European Central Bank has already pushed to widen the stablecoin yield ban, and as of September 1 only 39 EMTs had been issued under MiCA while no ARTs had been authorised — a gap reflected in the fact that only three of the top fifty stablecoins meet EU rules. The EBA said it will keep supporting the Commission's review with the aim of delivering a robust, future-proof framework for the EU crypto-asset sector.