USDC Significant E-Money Token: Dual Supervision From 12 November

On 14 October 2026 the European Banking Authority (EBA) announced that it has classified USDC, issued in the EU by Circle Internet Financial Europe SAS, as a significant e-money token under the Markets in Crypto-Assets Regulation (MiCAR). The EBA says 45 e-money tokens (EMTs) have been notified under MiCAR, and USDC is the first to be classified as significant. From 12 November 2026 the issuer moves into the dual supervision MiCAR provides for significant EMTs: own funds, reserve of assets, liquidity requirements and recovery and redemption plans pass from the French Autorite de controle prudentiel et de resolution (ACPR) to the EBA, while the ACPR keeps governance, qualifying holdings, fit and proper assessment, outsourcing and conflicts of interest.

The decision lands differently on three groups. The issuer, which Circle’s own terms call Circle France, picks up the Article 58(1) requirements that MiCAR attaches to electronic money institutions (EMIs) issuing significant EMTs, plus an EBA supervisory fee. Crypto-asset service providers (CASPs) and payment firms keep the data feeds and licensing positions they already have, but the token they handle will have an EBA-chaired supervisory college composed by reference to the largest custodians, trading platforms and payment service providers, ranked by custody value and transaction volume.

Several of the clocks that matter run from the date of the EBA decision itself, which the press release does not publish. Nor does it say which significance criteria USDC met. Both gaps shape what each group can plan for between now and 12 November.

Related reading: MiCAR Token Classification: Reporting Obligations for ARTs, EMTs, and Utility Tokens

How MiCAR turns an EMT into a significant e-money token

Article 56(1) of MiCAR requires the EBA to classify an EMT as significant where at least three of the seven criteria in Article 43(1) are met, either during the period covered by the first report after the token was offered to the public or admitted to trading, or across at least two consecutive reports. The criteria are the same ones used for asset-referenced tokens (ARTs):

Commission Delegated Regulation (EU) 2024/1506 gives criteria (e) and (f) their working content. For international scale it sets four core indicators: the token’s share of cross-border transaction value into and out of the Union, its estimated share of cross-border transactions used as a means of exchange, the global market capitalisation of the token, and the global market capitalisation of all tokens the issuer has issued. For interconnectedness it uses two core indicators built on the reserve, with ancillary indicators (ownership structure, concentration of reserve assets in financial institutions, portfolio overlap with other issuers) where the core ones are inconclusive. The Delegated Regulation sets no numeric thresholds for any of them.

The procedure is fixed in Article 56(3) to (6). The home competent authority reports the relevant data to the EBA and the European Central Bank (ECB) at least twice a year. When the EBA concludes that three criteria are met, it notifies a draft decision to the issuer, the competent authority and the ECB, each of which has 20 working days to comment. The final decision follows within 60 working days of that notification, and supervisory responsibilities transfer within 20 working days of the final decision being notified. The EBA’s own procedure, Decision EBA/DC/558 of 17 September 2024, runs the regular assessment once a year on two half-year reference periods (1 January to 30 June, 1 July to 31 December), with competent authorities remitting the data on 11 March and 11 September. Article 2(3) of that Decision lets the EBA run additional assessments, citing a rapid increase in holders or reserve size as an example.

The 14 October press release does not say which three criteria USDC met. The Article 56(7) derogation, which keeps supervision national where a significant EMT is denominated in an EU currency other than the euro and at least 80% of holders and transaction volume sit in the home Member State, has no application to a token referencing the US dollar.

The calendar for USDC between October 2026 and February 2027

The dates below come from the EBA press release, the reporting implementing technical standards (Commission Implementing Regulation (EU) 2024/2902, applied to non-EU-currency EMTs by Article 58(3) of MiCAR) and the EBA’s reporting Guidelines EBA/GL/2024/16.

A second set of deadlines is anchored to the decision date. The issuer has 10 calendar days from notification of the final decision to send the EBA the college information in Annex 4 of Decision EBA/DC/558 (Article 8). The EBA must establish the supervisory college within 30 calendar days of the decision (Article 119(1) of MiCAR). And the independent audit of the reserve of assets becomes six-monthly as of the date of the decision (Article 58(1), second subparagraph). The press release fixes only the end point of the transfer, 12 November.

Dual supervision: what the EBA supervises from 12 November

The press release splits the work as follows.

The operative text is Article 117(4) of MiCAR. Where an EMT issued by an electronic money institution is classified as significant, the EBA supervises the issuer’s compliance with Articles 55 and 58, and for that purpose exercises the competent authority powers in Articles 22 and 23, Article 24(3), Article 35(3) and (5), Article 36(10) and Articles 46 and 47. That list is longer than the four headings in the press release. Article 22 is the quarterly reporting obligation, Article 23 is the cap on tokens widely used as a means of exchange, and Article 24(3) lets the authority limit the amount issued or impose a minimum denomination after an ECB opinion. For a reporting team, the practical reading is that Article 22 data on USDC, and any Article 23 decision, sit within the EBA’s powers once the transfer takes effect, even though the press release summary does not name them.

Article 117(5) obliges the EBA to work in close cooperation with the issuer’s prudential supervisor and the authorities supervising it under the Second Electronic Money Directive (EMD2). Article 128 adds cooperation with authorities responsible for the issuer’s other activities, including third-country supervisors outside the college. USDC is also issued in the United States by Circle Internet Financial, LLC, and the EBA says it has signed a Memorandum of Understanding with the New York State Department of Financial Services to support supervision of cross-border stablecoin activity; Article 126 is the MiCAR basis for such agreements. Our note on the EBA-NYDFS stablecoin MoU covers its terms.

The mechanics of the handover are set by Decision EBA/DC/558. Within 20 working days of notifying the draft decision, the EBA prepares a “handover file” listing the information it needs and confirms its content with the outgoing authority. After the final decision, the EBA sends a formal request, and the outgoing authority has seven working days to deliver the file. Pending supervisory procedures are to be completed before the transfer date where possible. After the transfer, the EBA arranges an introductory meeting with the competent authority and the issuer to fix daily contact persons and secure channels for confidential information.

What Article 58 adds for an EMI issuing a significant e-money token

Article 58(1) swaps two parts of the e-money regime for MiCAR requirements written for ARTs. In place of the safeguarding rules in Article 7 of EMD2, it applies Articles 36, 37 and 38 and Article 45(1) to (4). In place of the own funds rules in Article 5 of EMD2, it applies Article 35(2), (3) and (5) and Article 45(5).

Reserve of assets and liquidity

Article 36 requires a reserve of assets that is legally segregated from the issuer’s estate and from the reserves of other tokens, so that creditors have no recourse to it in insolvency, and operationally segregated as well. Article 37 governs custody of reserve assets and Article 38 their investment. From Article 45, the issuer needs a remuneration policy that does not reward relaxed risk standards (45(1)), a liquidity management policy and procedures that keep the reserve resilient under liquidity stress (45(3)), and regular liquidity stress testing (45(4)). Depending on the stress test results, Article 45(4) lets the EBA strengthen the liquidity requirements referred to in Article 45(7)(b) and Article 36(6).

Article 58(1), second subparagraph, requires an independent audit of the reserve every six months as of the decision date. Under Article 36(10), results go to the supervisor within six weeks of the valuation reference date and are published within two weeks of that notification, and the power to delay publication in defined cases is one the EBA now exercises.

Own funds, stress add-ons and plans

Article 45(5) sets the reserve-based own funds percentage at 3% of the average amount of the reserve assets. Commission Delegated Regulation (EU) 2025/419 sets the route to that level: the competent authority of the home Member State notifies, within 25 working days of the classification being notified to the issuer, a timeframe of no more than six months for the issuer to adjust its own funds, and the issuer then has 25 working days from that notification to submit a detailed adjustment plan. Article 35(2) requires the own funds to be Common Equity Tier 1 under the CRR, after full deductions. Article 35(3) allows an add-on of up to 20% where the risk assessment points higher, and Article 35(5) requires an add-on of between 20% and 40% in certain circumstances, based on stress testing. Both add-on powers sit with the EBA under Article 117(4).

Recovery and redemption plans need careful framing. Article 55 already applied Articles 46 and 47 to every EMT issuer, with plans due within six months of the offer to the public or admission to trading. What moves on 12 November is the supervisor reviewing them.

The same caution applies to the reserve and own funds rules. Article 58(2) has always let a home competent authority require an electronic money institution with a non-significant EMT to comply with any of the Article 58(1) requirements to address liquidity, operational or reserve management risks. The press release says nothing on whether the ACPR used that power for USDC, so the size of the operational change at Circle France cannot be read from public sources. The legal change is clear: from classification, the requirements apply by force of Article 58(1), with the own funds level reached within the timeframe set under Delegated Regulation (EU) 2025/419, and the EBA supervises compliance with them from the transfer of supervisory responsibilities.

Reporting after the transfer: templates that switch on

Because USDC references a currency that is not an official currency of a Member State, Article 58(3) applies the Article 22 quarterly reporting regime to it regardless of significance, where the issue value exceeds EUR 100 million: number of holders, value issued and reserve size, average daily transactions, and an estimate of daily transactions used as a means of exchange within a single currency area. Commission Implementing Regulation (EU) 2024/2902 supplies the templates, and its Article 1(4) applies it mutatis mutandis to non-EU-currency EMTs. EBA/GL/2024/16 adds templates for own funds, the reserve maturity ladder and significance data.

Classification changes two things in that stack. Under Decision EBA/DC/558 (Article 7) and paragraphs 15 and 19 of the Guidelines, the data goes to the EBA once responsibilities have transferred, on the same quarterly reference and remittance dates. And some templates that an electronic money institution with a non-significant EMT does not file become applicable. The EBA’s illustrative template map for MiCAR (which states that MiCAR prevails in case of mismatch) shows the following for an electronic money institution issuing a non-EU-currency EMT:

The submission channel does not move. Decision EBA/DC/579 of 16 May 2025 set up the shared MiCA reporting platform on the EBA’s EUCLID infrastructure, and has competent authorities and the EBA tell issuers to report through it “regardless of a token’s significance”, on the dates in the ITS and the Guidelines. The EBA states that issuers report through its shared technical platform and that the resulting data are made available to relevant competent authorities according to their supervisory responsibilities under MiCAR. Our explainer on stablecoin reporting obligations for MiCAR e-money tokens walks through the Article 22 return in more detail.

CASPs: the same Article 22 feed, with college seats for the largest

For CASPs that hold, trade or transfer USDC, the classification creates no new template. Article 22(3) of MiCAR already requires CASPs providing services related to the token to give the issuer the information it needs for its report, including transactions outside the distributed ledger. For a non-EU-currency EMT, the EBA’s template map lists S 06.00 (holders), S 07.01 to S 07.05 (transactions, including those associated with use as a means of exchange, and the distributed ledger addresses used for client transfers) and S 08.00 (token held by the CASP). Quarterly templates go to the issuer by close of business on 21 April, 21 July, 21 October and 21 January; S 08.00 goes daily (Article 3(2) of CIR 2024/2902), in the format the issuer specifies (Article 4(2)). None of the CASP rows in the EBA’s map turns on whether the token is significant.

One definitional point affects what CASPs flag as means-of-exchange activity. Under the third subparagraph of Article 22(1), transactions associated with exchange for funds or other crypto-assets with the issuer or with a CASP do not count as uses as a means of exchange, unless there is evidence that the token is used to settle transactions in other crypto-assets.

The college is where CASP volumes start to matter. Article 119(2) lists, among the members, the competent authorities of the most relevant custodians of the reserve assets (point (d)), the most relevant trading platforms where the token is admitted (point (e)) and the most relevant CASPs providing custody and administration of the token for clients (point (h)). Commission Delegated Regulation (EU) 2025/297 defines “most relevant” by ranking: for a college of an electronic money institution issuing a significant EMT, the three entities holding the highest value of reserve assets in custody; the three trading platform operators with the highest average daily number of transactions, and the three with the highest average daily value; and likewise for custody CASPs. The EBA may invite only some of them where it considers those the only relevant ones in their category (Article 1(5)). A Member State’s authority can also request a seat where the token is used at large scale there, meaning holders amounting to at least 20% of the population on at least one day of the reference period, or an average of more than 1,250,000 transactions and EUR 250 million a day over the reference period, with at least one party located there (Article 2).

The seat belongs to the authority. A CASP whose supervisor joins the USDC college has no membership of its own; its supervisor takes part in the information exchange the college runs under Article 119(5).

Article 45(2), applied through Article 58(1), adds an obligation on the issuer that faces CASPs directly: a significant token must be capable of being held in custody by different authorised custody CASPs, including those outside the issuer’s group, on a fair, reasonable and non-discriminatory basis. The classification does not alter USDC’s standing under Article 48(1), which generally requires the EMT issuer to be an authorised credit institution or electronic money institution and to notify and publish a crypto-asset white paper, while expressly permitting other persons to offer the EMT with the issuer’s written consent, subject to Articles 50 and 53 and the statutory exemptions, so the issues covered in our note on ESMA’s opinion on non-MiCA-compliant ARTs and EMTs are a separate question from this decision.

Payment firms: PSD2 status, college seats and the means-of-exchange cap

Article 48(2) of MiCAR deems EMTs to be electronic money, which is why services with USDC can be payment services under the Second Payment Services Directive (PSD2). The EBA’s No Action letter, Opinion EBA/Op/2025/08 of 10 June 2025, advised competent authorities to treat transfers of EMTs carried out on behalf of clients, and custody and administration of EMTs, as payment services, and a custodial wallet that lets clients send EMTs to and receive them from third parties as a payment account. Exchange of crypto-assets for funds or for other crypto-assets is not deemed a payment service, and authorities were advised not to treat a CASP intermediating purchases of crypto-assets with EMTs as providing one. The No-Action Letter provided for a transition period ending on 2 March 2026; the EBA’s follow-up Opinion EBA/OP/2026/01 of 12 February 2026, addressing the end of that period on 2 March 2026, advised authorities to let applicants with duly submitted PSD2 applications continue pending a decision where specified conditions are met. Both opinions frame the question by the service performed with the EMT. The USDC classification, which concerns the issuer’s supervision, leaves a payment firm’s licensing analysis where it was.

Two parts of the significance regime do reach payment firms. First, Article 119(2)(f) gives a college seat to the competent authorities of the most relevant payment service providers providing payment services in relation to the significant EMT. Under Article 1(3) of Delegated Regulation 2025/297, those are the three providers with the highest average daily number of payment transactions in the token and the three with the highest average daily value, as “payment transaction” is defined in Article 4(5) of PSD2.

Second, the cap on tokens widely used as a means of exchange. Article 58(3) applies Article 23 to EMTs referencing a non-EU currency. Where the estimated quarterly average of transactions per day associated with use as a means of exchange within a single currency area exceeds 1 million transactions and EUR 200 million, the issuer must stop issuing the token and, within 40 working days, submit a plan to bring use back below those levels. Article 23(2) tells the authority to use the issuer’s figures, its own estimates or the ECB’s, whichever is higher. With the transfer, the EBA holds the Article 23 powers for USDC (Article 117(4)).

Payment use of USDC within the euro area is the activity that estimate is designed to capture, and CASPs report it to the issuer in template S 07.03, so relevant USDC payout or settlement transactions may contribute to the Article 23 assessment where they meet the applicable means-of-exchange definition. Not every transaction involving a payment service automatically qualifies for inclusion in that measure.

For other EMT issuers: fees, appeals and the annual reassessment

USDC is the first case, and the texts show what any electronic money institution approaching the Article 43(1) criteria should expect. The data that drives classification is already flowing: issuers with an issue value above EUR 100 million report the significance templates S 10.01 to S 10.03 under EBA/GL/2024/16, and issuers of EMTs referencing an EU currency also report the Article 22-style templates under paragraph 13 of the Guidelines so that the information needed for the significance assessment is available to the EBA. Article 57 offers a voluntary route, under which an issuer shows through a detailed programme of operations that it is likely to meet three criteria.

Supervisory fees follow classification. Under Article 137 of MiCAR the fee for a significant EMT issuer is proportionate to the size of issuance in exchange for funds. Delegated Regulation (EU) 2024/1503 takes that size from the latest available independent audit under Article 58 (Article 2(4)), prorates the first-year fee to the period between the effective transfer of supervision and year-end and requires that initial fee to be paid within 30 days of the EBA invoice (Article 2(6)); subsequent annual fees are payable by 31 March, with invoices issued at least 30 days before that deadline (Article 4). Supervision also brings the EBA’s enforcement toolkit; Recital 106 of MiCAR lists on-site inspections, supervisory measures and fines, and our coverage of the EBA’s MiCA fines methodology for significant token issuers sets out how it has proposed to calculate them.

Classification can also be reversed. Article 56(8) requires the EBA to reassess significant EMTs every year, using the twice-yearly data and the Article 22 reports. If the criteria are no longer met, the same draft decision, 20-working-day comment period and 60-working-day final decision apply, and responsibilities return to the national authority within 20 working days (Article 56(9) and (10)).

Frequently Asked Questions

Circle’s quarterly report for 30 September 2026 falls due on 11 November, a French public holiday. Which authority receives it?

Article 3(3) of CIR 2024/2902 moves a remittance to the following working day where the remittance day is a public holiday in the Member State of the competent authority receiving the report. 11 November 2026 is a Wednesday and a public holiday in France, which on that rule points to Thursday 12 November, the day the EBA’s supervision begins. The data travels through the shared EBA platform either way under Decision EBA/DC/579, but neither the ITS nor the press release says which authority follows up that quarter’s corrections. That is a question to settle with the ACPR and the EBA before the date.

Does the classification extend to Circle’s euro token, EURC, or to its crypto-asset services?

The press release concerns USDC only. Circle’s EEA terms identify EURC as another token issued by Circle France and state that its CASP authorisation was obtained on 24 April 2026. The AMF’s public register instead records 23 April 2026 and authorisation number N2026-005, explaining that Circle France was authorised by the ACPR, with the assent of the AMF, under the MiCAR Article 60 notification procedure. For ARTs, Article 45(6) applies the significant-issuer requirements to an issuer offering two or more ARTs once at least one of them is significant; Article 58(1) imports Article 45(1) to (5) for EMT issuers but not Article 45(6). Article 45(4), which is imported, requires stress tests to cover all of an issuer’s activities together where it offers two or more tokens or provides crypto-asset services, though the text was drafted for ARTs. How far those requirements reach beyond USDC is not settled by the published texts.

A bank issues a euro EMT that meets three criteria. Does the EBA take over its supervision?

Article 56 classification applies to any EMT, but the EBA supervisory role in Article 117(4) and the Article 58(1) requirements are written for electronic money institutions. The EBA’s final report on the college standards (EBA/RTS/2024/14) states that supervisory responsibility for a credit institution issuing a significant EMT stays with its competent authority. A college is still established for each issuer of a significant EMT, and Delegated Regulation 2025/297 has a separate custody ranking for credit institution issuers, based on the funds received in exchange for the tokens.

Our CASP has received a data request from the issuer that goes beyond the Article 22 templates. Where does it come from?

Article 8 of Decision EBA/DC/558 requires issuers of newly significant tokens to send the EBA the Annex 4 information needed to set up the college within 10 calendar days of the final decision, and its recitals state that this includes information the issuer collects from relevant CASPs. The legal duty in that Decision sits with the issuer; the CASP’s own statutory duty to supply data remains Article 22(3).

Can Circle contest the classification?

Article 10 of Decision EBA/DC/558 lets issuers and competent authorities make a reasoned request to be heard and to access the assessment file, and states that an appeal under Article 60 of the EBA Regulation (Regulation (EU) No 1093/2010) must be filed within three months of notification of the decision.

Does significance change PSD2 safeguarding for a CASP that also holds a PSD2 licence and keeps USDC for clients?

The No Action letter advises authorities not to prioritise supervision of PSD2 Article 10 safeguarding for EMTs held by CASPs or payment service providers, pointing instead to the MiCAR safekeeping rules in Article 70(1). That advice is tied to the holder’s service. The classification changes the issuer’s reserve and liquidity rules under Article 58, which protect redemption at the issuer level and do not alter the safekeeping position of a firm holding tokens for clients.

Related Articles

• EBA-NYDFS Stablecoin MoU: What EU EMT Issuers Should Know: the cross-border supervisory cooperation arrangement the EBA cites in its USDC announcement.
• Stablecoin Reporting Obligations: MiCAR E-Money Tokens and the PSD3 Shift: how EMT issuers file the Article 22 quarterly data and what PSD3 changes for payment institutions.
• EBA MiCA Fines Methodology: Enforcement Risk for Significant Token Issuers: the EBA’s proposed approach to calculating fines for significant ART and EMT issuers.
• MiCA Review: The EBA’s Priorities for Token Issuers and CASPs: the EBA’s response to the MiCA review, including multi-issuer stablecoins and reporting mandates.
• Non-MiCA-Compliant ARTs and EMTs: ESMA’s Three-Month Ceiling: what CASPs should review for tokens whose issuers lack MiCAR authorisation.

Key Takeaways

• From 12 November 2026, address USDC own funds, reserve, liquidity and recovery or redemption plan matters to the EBA; governance, qualifying holdings, fit and proper, outsourcing and conflicts of interest stay with the ACPR.
• EMI issuers nearing the Article 43(1) criteria: the competent authorities’ next half-yearly significance data remittance to the EBA is 11 March 2027, covering July to December 2026.
• CASPs: the Q3 2026 USDC data is due to the issuer by close of business on 21 October 2026, with no template added by the classification.
• Issuer reporting teams: prepare the 31 December 2026 reference-date return for remittance by 11 February 2027. Confirm the full S 02.00 scope and the applicability of S 09.01 and S 09.02 following significance, and reconcile S 03.01, S 03.02 and S 05.00 against the existing French ACPR reporting instruction. The reserve-composition templates may already have been required before the supervisory transfer.
• Payment firms in the top three by average daily USDC payment transactions, by number or by value, are the ones whose supervisors Delegated Regulation 2025/297 points the EBA to when composing the college.
• From 12 November 2026 the EBA exercises Article 23 powers for USDC. Issuance must stop where the estimated quarterly averages of daily means-of-exchange transactions within a single currency area exceed both 1 million transactions and EUR 200 million; a plan to bring activity below those thresholds must be submitted within 40 working days.

Sources and References

• EBA press release, “The EBA classifies USDC as the first significant e-money token in the European Union” (14 October 2026): eba.europa.eu
• Regulation (EU) 2023/1114 on markets in crypto-assets (MiCAR), Articles 22, 23, 24, 35, 36, 43, 45, 48, 55, 56, 57, 58, 117, 119, 126, 128 and 137 and Recital 106: EUR-Lex
• Commission Delegated Regulation (EU) 2024/1506 of 22 February 2024 specifying certain criteria for classifying ARTs and EMTs as significant: EUR-Lex
• Commission Delegated Regulation (EU) 2024/1503 of 22 February 2024 on the fees charged by the EBA to issuers of significant ARTs and EMTs, Articles 2 and 4: EUR-Lex
• Commission Delegated Regulation (EU) 2025/297 on regulatory technical standards for consultative supervisory colleges, Articles 1 and 2: EUR-Lex
• Commission Delegated Regulation (EU) 2025/419 of 16 December 2024 on the procedure and timeframe for an issuer of ARTs or EMTs to adjust the amount of its own funds, Articles 1 and 2: EUR-Lex
• Commission Implementing Regulation (EU) 2024/2902 of 20 November 2024 on reporting related to ARTs and to EMTs denominated in a currency that is not an official currency of a Member State, Articles 1 to 4: EUR-Lex
• EBA, Implementing Technical Standards on reporting on ARTs and EMTs denominated in a non-EU currency (page with annexes): eba.europa.eu
• EBA, Final Report on Guidelines on templates to assist competent authorities in performing their supervisory duties regarding issuers’ compliance under Titles III and IV of MiCAR, EBA/GL/2024/16 (18 December 2024): EBA (PDF)
• EBA, Explainer: MiCAR templates (December 2024, illustrative): EBA (PDF)
• EBA Decision EBA/DC/558 of 17 September 2024 on the procedure for the classification of ARTs and EMTs as significant and the transfer of supervisory powers: EBA (PDF)
• EBA Decision EBA/DC/579 of 16 May 2025 concerning the MiCA reporting platform: EBA (PDF)
• EBA, Final Report on draft RTS on supervisory colleges under Article 119(8) of MiCAR, EBA/RTS/2024/14 (19 June 2024): EBA (PDF)
• EBA, The EBA’s supervisory role under MiCA: eba.europa.eu
• EBA Opinion EBA/Op/2025/08 (No Action letter) on the interplay between PSD2 and MiCA for CASPs that transact EMTs (10 June 2025): EBA (PDF)
• EBA Opinion EBA/OP/2026/01 on supervisory priorities at the end of the No Action letter transition period (12 February 2026): EBA (PDF)
• Circle, EEA terms (Circle Internet Financial Europe SAS regulatory status, tokens issued and CASP licence; version dated 7 July 2026): circle.com
• AMF, public register of crypto-asset service providers, entry for Circle Internet Financial Europe SAS (authorisation N2026-005): amf-france.org
• ACPR, Instruction no. 2025-I-14 on reporting by issuers of asset-referenced tokens and e-money tokens under Titles III and IV of MiCAR, Article 4: acpr.banque-france.fr
• Service-Public.fr, public holidays in France in 2026 (Code du travail, Articles L3133-1 to L3133-3): service-public.gouv.fr

Before 12 November: the USDC files each team should have ready

The transfer date and the reporting dates around it are published; the decision date is the missing input. The issuer’s six-monthly audit cycle, its 10-day college return and the 30-day deadline for constituting the college all run from it, and none of them can be placed on a calendar until it is known. The first step for issuers, CASPs and payment firms alike is to obtain that date, then to confirm with the ACPR and the EBA, before 11 November, which authority handles the 30 September 2026 quarter.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.