SRB publishes its response to Commission consultation on Markets in Crypto-Assets Regulation (MiCA)

The Single Resolution Board (SRB) has submitted its response to the European Commission’s targeted consultation on the review of the Regulation on Markets in Crypto-assets (MiCA). 

From the resolution and crisis management perspective, stablecoin-related activities raise questions: 

• For non-credit institutions, beyond some supervisory and recovery measures, there is no dedicated resolution regime for systemic activity. 
• For credit institutions, stablecoins could affect resolvability via liquidity, operational and reputational risks: (1) as issuers; (2) as institutions with funding (including via deposit) from token issuers and service providers (CASPs); (3) as providers of services (e.g. custody, payments or reserve management) and (4) as intermediaries holding stablecoins on balance sheet.

The SRB’s response to the MiCA consultation is mainly related to the first two roles and focuses on resolution-related considerations from the perspective of the Banking Union resolution authority. Moreover, it also covers the broader question of crisis management for systemic stablecoins.

The SRB’s response proposes: 

1. Targeted data and information sharing mechanisms between competent authorities and resolution authorities on material token linkages, operational dependencies and concentration risks involving credit institutions; 
2. Coordination between MiCA supervisors and resolution authorities, including strengthening coordination mechanisms and timely notification when redemption plans are activated; 
3. Strengthening interaction between MiCA, BRRD and SRMR, particularly for the treatment of reserve deposits, asset segregation, insolvency protections, bankruptcy remoteness, ranking of claims and depositor protection; and 
4. Proportionate crisis management dimension for significant tokens issued by non-credit institutions.  

The SRB stands ready to support any future European Commission review or follow-up work on the issues explored in this response, in particular, where they relate to the interaction between MiCAR and the BRRD/SRMR resolution framework, the treatment of stablecoin-related exposures in resolution, and the implications for resolvability and crisis management.

SRB response to the targeted consultation on the review of the Regulation on Markets in Crypto-assets (MiCA)

PDF | 243.26 KB | Publishing date: 08/10/2026

This document is not intended to create any legally binding effect, may not be relied upon for any legal purposes, does not establish any binding interpretation of EU or national laws and does not serve as, or substitute for, legal advice. It shall not be considered as predetermining the position that the SRB may take in specific cases, where the circumstances of each case will also be considered. It is intended solely to support ongoing discussions on the review of the Markets in Crypto‑Assets Regulation (MiCA)