GBBC Responds to European Commission Consultation on the Review of MiCA
Published
GBBC has responded to the European Commission’s targeted consultation on the review of the Markets in Crypto-Assets Regulation (MiCA).
Our response recommends targeted improvements to classification, prudential requirements and implementation, reflecting the range of activities and business models across the digital asset industry.
Key recommendations include:
Preserve a technology-neutral regulatory boundary. Tokenised financial instruments should remain subject to existing securities legislation, supported by clearer guidance and consistent supervisory decisions on borderline cases.
Calibrate stablecoin safeguards to the risks involved. Capital, reserves and liquidity requirements should work together. Cross-border issuance needs clear responsibility for redemption, enforceable reserve rebalancing and an accountable EU supervisory framework, with recognition of comparable overseas safeguards where appropriate.
Reduce duplication between MiCA and payment-services rules. Common guidance should clarify which activities fall under each regime, while streamlined authorisation should maximise reuse of existing documentation.
Strengthen legal certainty. Targeted EU rules should address transfer, collateral, custody and insolvency, alongside a consistent approach to determining which jurisdiction’s law applies.
On remuneration, GBBC supports assessing a narrowly defined model with safeguards for reserve backing, liquidity and immediate redemption. The response also recommends a functional approach to decentralised finance, voluntary certification that supports due diligence, and confirmation that tokenisation alone does not change a deposit’s legal classification.
These recommendations aim to make the framework more predictable and proportionate while preserving enforceable rights, consumer protection and financial stability.
Read GBBC’s full response here.