Circle Wants the EU to Lower the Bar That's Keeping Euro Stablecoins Tiny
On March 20, Circle submitted formal feedback to the European Commission on its proposed Market Integration Package — a broad policy initiative to strengthen European capital markets. The headline request: lower the market cap thresholds that currently prevent any euro stablecoin from being used in EU securities settlement.
The Regulatory Trap
Under the Central Securities Depositories Regulation (CSDR), only "significant" e-money tokens can be used to settle securities transactions. Under MiCA's classification framework, an EMT earns "significant" status only after exceeding thresholds that no euro stablecoin has yet come close to reaching. Circle's submission put it bluntly: "No euro-denominated EMT is close to reaching the market cap threshold."
The numbers support that. According to Cointelegraph's coverage of the filing, Circle told the Commission that fixed thresholds create a "chicken-and-egg scenario that stifles their growth." Verified market data shows EURC — currently the largest euro stablecoin — carries a market cap of approximately $420 million. The MiCA significant-EMT threshold sits in the billions-of-euros range, meaning EURC is a small fraction of what's required. Euro stablecoins need to prove their value in settlement to grow, but they need to grow before they can settle.
What Circle Is Asking For
Rather than fixed market cap thresholds, Circle recommends "adaptive thresholds" evaluated through supervisory assessments based on market uptake and liquidity conditions. The company also wants the DLT Pilot Regime — which allows blockchain-based financial market infrastructure to operate under relaxed EU rules — expanded to include crypto-asset service providers. Currently, the Pilot Regime is limited to credit institutions, which locks out non-bank stablecoin issuers.
The submission was filed in response to the Market Integration Package, a policy document spanning capital markets, savings, and retail financial services across the EU. Stablecoins aren't its main subject. Circle wants them included anyway.
The Legitimate Concern Behind the Lobbying
Strip away the self-interest and there's a real regulatory design problem. MiCA was built with large, systemically important stablecoins in mind — the kind that could destabilize financial markets if they failed. High classification thresholds make sense as risk controls for trillion-dollar tokens. But applying those same thresholds to block small euro stablecoins from settlement use creates a permanent moat for whoever got big first.
In the stablecoin market, who got big first is USDT and USDC — both dollar-denominated, both far above any EU threshold. If EU securities settlement requires tokens that no euro stablecoin can reach, the practical outcome is that EU capital markets run on dollar rails. That's the opposite of what the EU's financial sovereignty advocates want. Circle's interest and European interest are, on this specific point, aligned.
Why Brussels May Not Move Fast Enough
Circle's feedback is one voice among many in an open consultation. The Commission isn't bound to adopt any of it, and EU regulatory cycles move slowly. MiCA itself took years to finalize and only came into full effect in December 2024. Amendments to its provisions are not imminent. The same week Circle filed this feedback, it was also lobbying the UK Parliament (March 18) and backing the US GENIUS Act in Washington. The company that writes the earliest regulatory framework gets the market. Circle is working every room simultaneously.