On 24 September 2026, the European Banking Authority (EBA) published its response to the European Commission’s targeted consultation on the review of the Markets in Crypto-Assets Regulation (MiCA). The response highlights potential changes concerning stablecoin structures, crypto-asset classification, lending and access to decentralised finance (DeFi).
For businesses operating in Cyprus and across the EU, these recommendations provide an indication of areas that may influence future regulatory requirements. The proposals do not themselves amend MiCA or introduce immediate additional obligations.
The EBA considers the existing framework for issuers of asset-referenced tokens (ARTs) and electronic money tokens (EMTs) broadly appropriate. However, it recommends strengthening safeguards for third-country multi-issuer stablecoin schemes. It also calls for a review of reserve requirements, including the minimum proportion held as bank deposits, while preserving effective risk management.
Crypto-asset lending is another priority. The EBA recommends assessing whether MiCA should cover the intermediation of crypto-asset borrowing and lending, together with requirements for crypto-asset service providers (CASPs) facilitating client access to DeFi lending protocols. This could include access through a provider’s interface or products offering exposure to such protocols.
Potential measures identified for consideration include suitability assessments, leverage limits, enhanced risk disclosures and restrictions concerning lending involving unauthorised ARTs or EMTs. The EBA also raises the possibility of a certification regime for DeFi lending protocols. These measures remain subject to further assessment and any subsequent legislative developments.
The EBA highlights that difficulties in classifying crypto-assets under MiCA create challenges for firms and supervisors, leading to avoidable costs and delays in launching products. These challenges can impede innovation and undermine the competitiveness of the EU market. The EBA therefore recommends that the European Commission consider clarifying MiCA’s scope and definitions to support more consistent classification.
The response also recommends reviewing reporting arrangements for issuers and CASPs to support effective supervision and risk monitoring.
From a practical compliance perspective, FiveComply recommends that firms monitor these developments and assess their relevance to existing operations and planned services, including when preparing or reviewing business plans and licensing assessments.
Firms should also distinguish between obligations already applicable to their activities and potential future changes. This will help management assess the implications of the MiCA review without treating consultation recommendations as enacted requirements.
FiveComply can assist businesses in assessing their regulatory obligations, preparing licensing documentation and reviewing compliance arrangements in light of developments in the EU crypto-asset framework.
