Circle, the issuer of USDC and EURC, has asked the European Commission to revise Markets in Crypto-Assets Regulation (MiCA) rules for foreign stablecoins, while the European Securities and Markets Authority (ESMA) has proposed prohibiting every licensable crypto-asset service involving stablecoins that fail applicable MiCA requirements. Circle supports a recognition regime for foreign issuers, continued multi-issuance and replacement of mandatory commercial-bank reserve deposits with less rigid liquidity requirements. ESMA’s proposal would extend restrictions beyond offers and trading to custody and transfers, potentially preventing licensed providers from safeguarding or moving existing balances after trading pairs disappear. ESMA’s September 30, 2026 submission is a policy recommendation rather than enacted law and sets no implementation date, withdrawal exception or wind-down mechanism. Circle said only three of the 25 largest stablecoins by market capitalization were regulated under MiCA, including USDC and EURC, while ESMA said the absence of broader service restrictions could create disparities and regulatory arbitrage. Any legislative amendment would need to reconcile new restrictions with MiCA obligations to return client assets.