The European Banking Authority has asked the European Commission to conduct a cost-benefit analysis of possible MiCA (Markets in Crypto-Assets) changes covering crypto-asset service providers, or CASPs, that connect customers to DeFi (decentralized finance) lending. The EBA’s September 24 response does not itself change lending rules; it asks the Commission to assess whether legislation is warranted. Potential measures include adding intermediated crypto borrowing and lending to the CASP services listed under MiCA and imposing requirements on firms that facilitate access to DeFi protocols through interfaces or products. The Commission would consider the scale of the activities, retail participation and the materiality of related risks. Possible safeguards include suitability tests, leverage caps, expanded disclosures, warnings that truly decentralized protocols may lack regulatory protections, and certification of lending protocols for cyber resilience. The EBA also raised a separate restriction on CASPs intermediating or facilitating borrowing and lending involving asset-referenced or e-money tokens whose issuers lack required MiCA authorization. The review reflects risks including incomplete information on fees, yields and collateral requirements, amplified losses from leverage, commingling, outages, hacks, poor recordkeeping, absent creditworthiness checks and over-indebtedness. The Commission’s targeted consultation closes on September 30 at 11:59 p.m. Central European Summer Time. Feedback will inform its report on MiCA’s application and crypto-market developments, which the Commission says may be accompanied by a legislative proposal if warranted. The eventual reach of any access rule, including how it would apply to interfaces, intermediated loans, DeFi exposure products and direct smart contract use, remains undecided.