Circle has submitted recommendations to the European Commission regarding the MiCA regulatory review, advocating for the retention of a multi-issuer structure for stablecoins. The company noted that while MiCA has established a first-mover advantage with approximately 30 authorized e-money tokens, only three of the top 25 global stablecoins by market cap—USDC, USDG, and EURC—are currently regulated under the framework. Circle proposes an equivalence and recognition regime similar to EMIR and MiFIR, allowing foreign-regulated stablecoins to operate alongside EU-authorized entities. On reserve requirements, Circle warned that mandating issuers to hold at least 30% of reserves in commercial bank deposits increases counterparty and credit risk. The firm supports the European Central Bank reconsidering this requirement and recommends removing two concentration rules from EBA technical standards to mitigate systemic risks and improve regulatory alignment with global markets.