Stablecoin Rules Tighten at Both Ends: EBA Absorbs USDC, FSB Flags Türkiye

On November 12, the EU moved the largest dollar stablecoin by circulation into its highest supervisory tier; on November 11, the FSB named Türkiye, the market with the world’s most intense stablecoin demand, as still lacking an issuer regime. Both ends of the regulatory spectrum tightened in the same week.

EBA Takes Over USDC: Europe’s First “Significant” Stablecoin Enters Dual Supervision

On November 12, 2026, the European Banking Authority (EBA) formally began direct supervision of Circle Internet Financial Europe SAS, the issuer of USDC. Under Article 117(4) of MiCA, the EBA took over direct oversight of own funds, reserve assets, liquidity requirements and recovery and redemption plans from France’s Autorité de Contrôle Prudentiel et de Résolution (ACPR). The ACPR continues to supervise corporate governance, qualifying holdings, fit-and-proper checks, outsourcing and conflicts of interest. USDC thus becomes the first of the 45 e-money tokens (EMTs) notified under MiCA to be classified “significant” and placed under dual supervision.

The upgrade began with the EBA’s classification decision on October 14. Article 56 of MiCA applies the tests in Article 43(1): more than 10 million holders; token value, market capitalisation or reserves above EUR 5 billion; more than 2.5 million daily transactions or EUR 500 million in daily transaction value; a gatekeeper issuer; international use in payments and remittances; links to the broader financial system; and an issuer that issues other tokens while providing crypto-asset services. At least three of the seven criteria must be met to qualify as “significant.” The EBA has not disclosed which criteria USDC met, citing the indicators in Commission Delegated Regulation (EU) 2024/1506, and reassesses the label every year. “Significant” is therefore not a terminal status but a rolling identity reviewed by scale.

For the issuer, the real change is cost. Article 58 replaces the e-money directive’s capital and safeguarding provisions with MiCA’s stricter versions: minimum own funds shift from 2% of average outstanding e-money (E-Money Directive Art. 5(3)) to 3% of average reserve assets (MiCA Art. 45(5)). For every $1 billion of average reserves, Circle SAS’s minimum own funds rise from roughly $20 million to $30 million, a 50% increase. Under Article 35(3), supervisors can add a buffer of up to 20%, or $36 million per $1 billion. Independent reserve audits are now required every six months instead of annually, and Circle SAS pays an annual EBA supervisory fee proportional to issuance (MiCA Art. 137, detailed in Delegated Regulation 2024/1503).

A liquidity management policy with regular stress tests is now mandatory (Arts. 45(3)-(4)), and significant tokens must be holdable at other custodians on fair terms (Art. 45(2) interoperability duty). Circle acknowledged in its third-quarter 10-Q, filed November 4, that it is still evaluating the impact of the classification and the transition, and that it may need to hold more capital or liquidity in the EU. According to DefiLlama, total USDC in circulation stood at about $69.8 billion on November 12, but the reserves held by the EU issuer are not disclosed separately, so the exact capital gap is hard to estimate.

Just as notable is the memorandum of understanding the EBA signed with the New York State Department of Financial Services (NYDFS), which oversees Circle’s US business. The EBA now sees the EU reserve directly, and the two supervisory perspectives are aligned through a cross-border information-sharing framework. This means USDC’s reserve composition, audit results and risk assessments will be examined in tandem across the Atlantic, and EU prudential standards are starting to spill over into how the US issuing entity is supervised. For holders, the token itself is unchanged: EEA holders can still redeem at par at any time, and USDC remains outside the EU deposit guarantee and investor compensation schemes.

Put this back into the timeline: on October 1, Circle filed comments with the European Commission’s MiCA review opposing the bank-deposit floor of 30% (60% for significant tokens) and asking for a flexible liquidity standard instead; 13 days later, the EBA classified it as the only token subject to the stricter prudential requirements. Circle and Tether disagree on almost everything except this deposit floor, which both want gone. Now that the EBA supervises these reserves directly, any relaxation would require both a new law and a new supervisor’s sign-off. The deposit-floor dispute will not loosen simply because of the “significant” label.

FSB Flags Türkiye: The Market That Most Needs a Stablecoin Regime Has No One

On November 11, the Financial Stability Board (FSB) published its second peer review of Türkiye. The report acknowledges meaningful progress by Turkish authorities in registration and licensing of crypto-asset service providers (CASPs), strict custody separation, the ban on using crypto for domestic payments, and the build-out of a central data platform. It leaves one blunt finding: “Stablecoins are not subject to comprehensive regulation, supervision and oversight.” And the FSB’s framing of the gap carries more weight than the data itself.

The mismatch in market scale is the core tension in the report. Turkish authorities report 7.1 million crypto-asset accounts and 5.3 million account holders, with roughly $200 billion in annual transactions in 2025. Dollar-pegged tokens are widely used to hedge against lira depreciation and domestic inflation: on-chain data shows USDT accounts for about 7% of Turkish holdings, and globally, Turks spend the largest share of GDP on stablecoin purchases of any economy. In contrast, BiLira (TRYB), the only stablecoin issued by a domestic entity, has a market capitalisation of only about $5.9 million. Demand is among the world’s highest; supply is close to zero; and in between sits an entire zone with no issuance rules.

The FSB’s five recommendations share one thread: upgrading the regime from “registration” to “supervision.” Concretely: complete the transition from interim registration to licensing on a defined schedule and publish expected timelines for each stage; clear the audit backlog and standardise proof-of-reserve presentation and incident reporting; improve the completeness and timeliness of filings to the central registry system (KVMKS); assess how bank crypto exposures are treated, including possible future alignment with the Basel Committee’s SCO60 standard; and at the issuer level, require redemption rights, effective stabilisation mechanisms and prudential requirements, clarify how stablecoins interact with payments and e-money law, and impose targeted reserve-composition and transparency expectations on foreign-issued, foreign-currency tokens circulating through domestic providers, with stronger cooperation with the issuer’s home supervisor.

The report also exposes the concrete shape of the blind spot. Türkiye launched weekly reporting through the Crypto Asset Central Registry System (KVMKS) in early 2026, but the platform only pulls data from domestically licensed platforms; it cannot see foreign exchanges or self-custody wallets. On-chain data suggests Binance Global holds roughly 70% of the Turkish market, leaving a wide visibility gap between regulatory data and the real market. Domestic platforms are only approved for spot trading, so demand for leverage and derivatives flows to offshore venues. The largest domestic platform, BtcTurk, has suffered three security incidents in two years, with the most recent costing about $48 million. The licensing process itself is stuck on bottlenecks: TÜBİTAK technical reviews carry no statutory time limit, independent ICT audit capacity is weak, and custody rules require platforms to hold no more than 5% of client assets in their own wallets, cap custodian hot wallets at 5% (flexible to 10%), and return at least 95% of assets to custody at daily settlement. Six banks have received preliminary approvals from the Banking Regulation and Supervision Agency (BRSA), and three have been deemed “suitable” by the Capital Markets Board (CMB), but none had begun serving clients as of the report, with the full path from approval to operation expected to take 12 to 18 months.

Türkiye is not without foundations. The Financial Crimes Investigation Board (MASAK) already caps stablecoin transfers (crypto-to-crypto at $3,000 daily and $50,000 monthly) and maintains a direct AML/CFT information-sharing and asset-freezing channel with Tether; an amendment to the central bank’s Regulation No. 31676 on payment services and e-money allows qualifying currency-pegged stablecoins to be treated as equivalent to e-money, opening a pathway to payments. But as the report notes, the implementing rules have not been published, leaving issuers facing an e-money regime “with the details unwritten.” The FSB’s information reflects conditions as of August 2026, was discussed by the Standing Committee on Standards Implementation in September, and was released after the October G20 finance ministers’ meeting. This is not a rulemaking document, but a check-up on G20 framework implementation with strong directional signals for the next phase of legislation.

Key Takeaways for Practitioners