The European Banking Authority (EBA) has called on EU policymakers to consider bringing crypto-asset lending within the Markets in Crypto-Assets Regulation as part of a wider review of the bloc’s digital asset rulebook.
In its response to the European Commission’s targeted consultation, published on 24 September 2026, the EBA argued that the existing framework leaves important consumer-protection gaps as new products and business models continue to appear.
MiCA already provides a comprehensive regime for many crypto activities, including the issuance of asset-referenced tokens and electronic money tokens and the provision of crypto-asset services.
Yet the authority noted that lending and borrowing of crypto-assets were deliberately left outside the original text.
Recital 94 of the regulation stated that such activities should not be addressed by MiCA and that their feasibility and necessity should be assessed later.
That assessment is now under way.
The EBA observed that crypto lending, including the use of so-called stablecoins, has grown in both volume and geographic reach. Earlier joint work with the European Securities and Markets Authority found that intermediated borrowing and lending was already taking place in at least 16 member states.
The authority also highlighted the increasing role of regulated crypto-asset service providers that offer clients access to decentralised-finance lending protocols.
Easier interfaces and artificial intelligence tools, it said, are blurring the line between centralised and decentralised activity.
Because these services can expose retail users to leverage, opaque collateral rules, incomplete information on fees and yields, operational failures and potential losses from fraud or hacks, the EBA recommended that the Commission carry out a robust cost-benefit analysis.
Possible legislative options include adding the intermediation of borrowing and lending to the list of regulated crypto-asset services and imposing specific obligations on firms that facilitate access to DeFi protocols.
Measures under consideration could include suitability assessments, leverage limits, enhanced disclosure and, in some cases, a certification regime for protocols that are not fully decentralised.
The lending recommendation sits alongside several other priorities identified by the EBA.
The authority judged the current requirements for asset-referenced and e-money tokens to be broadly appropriate, but it called for stronger rules on third-country multi-issuer stablecoin schemes, which it said pose significant to very significant risks.
It also suggested a review of reserve requirements, particularly the minimum share of reserves that must be held as bank deposits, while preserving effective liquidity management.
As of 1 September 2026, 39 electronic money tokens had been issued under MiCA, while no asset-referenced tokens had received authorisation.
A further concern is the classification of crypto-assets.
Unclear boundaries between MiCA and other EU financial services legislation, including MiFID, create avoidable costs and delays for firms launching products.
The EBA therefore asked the Commission to clarify the scope and definitions of the regulation in order to support consistent supervision, reduce legal uncertainty and protect the competitiveness of the EU market.
It also recommended a review of reporting requirements for issuers and service providers so that supervisors have better data for risk monitoring.
The consultation remains part of a broader process.
MiCA’s main provisions applied from 30 December 2024, with the stablecoin titles having taken effect six months earlier.
The Commission’s review is intended to determine whether the framework remains fit for purpose as the market evolves. The EBA said it stands ready to support any further analysis the Commission considers necessary, with the aim of producing a proportionate and future-proof regime.