Circle’s quarterly filing disclosed that, effective Nov. 12, supervisory responsibility for the financial safeguards of EU‑issued USDC will be transferred from France’s Autorité de Contrôle Prudentiel et de Résolution (ACPR) to the European Banking Authority (EBA). The arrangement, agreed upon since October, follows the EBA’s classification of EU‑issued USDC as a significant e‑money token under the Markets in Crypto‑Assets Regulation (MiCA). Circle notes that USDC is the first token to receive this designation.
Under the new oversight split, the EBA will directly supervise Circle Internet Financial Europe SAS (Circle France)’s regulatory capital, reserve assets, liquidity requirements, and recovery/redemption plans. The ACPR will retain governance duties, including qualifying holdings, fit‑and‑proper assessments, outsourcing arrangements, and conflict‑of‑interest monitoring. Circle therefore faces dual supervision: financial‑safeguard oversight from the EBA and governance oversight from the ACPR.
The shift could require additional capital or liquidity to be held within the EU and increase compliance costs, though Circle has not provided a quantified estimate of the impact. The filing also reports a memorandum of understanding between the EBA and the New York State Department of Financial Services to facilitate cross‑border cooperation on stablecoin supervision.
Circle warns that the significant‑token classification may impose higher prudential requirements under MiCA, potentially affecting its financial results. No revised redemption terms or new holder fees are announced, and existing cash‑out arrangements for holders remain unchanged.
Circle’s disclosed chronology14 OCT 202612 NOV 2026Classification announcedDisclosed handover dateSignificant e‑money tokenDual supervision
Circle’s disclosed chronology14 OCT 2026Classification announcedSignificant e‑money token12 NOV 2026Disclosed handover dateDual supervision
Explore the supervisory split
Explore the supervisory splitFinancial safeguardsGovernance & related
Circle says own funds, reserves, liquidity, and recovery/redemption plans transfer from the ACPR to the EBA.
EBA financial responsibilities for Circle FranceACPRFRANCEEBAEUROPEAN UNIONRetains other remitFinancial safeguardsSHARED SUBJECT OF SUPERVISIONCircle FranceEU issuer of USDCFinancial safeguardsOwn funds / regulatory capitalReserve assetsLiquidity requirementsRecovery & redemption plansEBA financial responsibilities for Circle FranceACPRFranceEBAEuropean UnionSHARED EU ISSUERCircle FranceEU‑issued USDCEBA: financial safeguardsOwn funds / regulatory capitalReserve assetsLiquidity requirementsRecovery & redemption plans
France’s ACPR retains governance, qualifying holdings, fit and proper assessments, outsourcing and conflicts of interest.
ACPR retained responsibilities for Circle FranceACPRFRANCEEBAEUROPEAN UNIONRetains this remitOther supervisorSHARED SUBJECT OF SUPERVISIONCircle FranceEU issuer of USDCGovernance & relatedGovernance • qualifying holdingsFit and proper assessmentsOutsourcingConflicts of interestACPR retained responsibilities for Circle FranceACPRFranceEBAEuropean UnionSHARED EU ISSUERCircle FranceEU‑issued USDCACPR: retained oversightGovernanceQualifying holdingsFit and proper assessmentsOutsourcing • conflicts of interest
Financial safeguards move to the EBA; France’s ACPR retains governance and related oversight.
EU issuer only. Based on Circle’s disclosed arrangements, with November 12 as the effective date. Connections show supervisory responsibility, not funds moving between regulators.
The filing also reports an EBA memorandum of understanding with the New York State Department of Financial Services to facilitate cooperation and information exchange on cross‑border stablecoin activities.
The memorandum covers cooperation and information exchange, as well as the allocation of supervisory responsibilities for the EU issuer.
Circle says the significant‑token classification may bring increased regulatory capital, reserve, liquidity and other prudential requirements under MiCA. These could require additional capital or liquidity in the EU, raise compliance costs or adversely affect its business and financial results.
The disclosure provides no estimate of possible additional capital, liquidity, or compliance spending, and identifies no quantified financial charge arising on Nov. 12. Whether additional commitments will be needed, and their potential size, remain unresolved in that assessment.
Supervision of redemption plans concerns the issuer’s safeguards, and the note announces no revised cash‑out terms or new holder fees. The disclosure identifies the responsible supervisors but does not specify any change to holders’ redemption arrangements.