Becoming a Heavyweight Stablecoin Issuer : Criteria & Consequences
- BECTRA
- Mar 31
- 2 min read
"When a 45-ton sperm whale comes from starboard, it has right of way. Come to think of it, it does from port side too." Size matters !
A stablecoin issuer may be classified as “of significant importance” by the European Banking Authority (EBA). This classification strengthens the regulatory framework and transfers supervisory responsibility from national authorities (like the AMF or ACPR) to the EBA.
🧩 What are the EBA’s classification criteria ?
To be considered a significant stablecoin issuer, the EBA requires that the entity meet at least three of the following seven criteria, based on one or two annual information reports:
1. 📈 High number of users
The token is held by more than 10 million unique users.
2. 💶 Large asset value or market capitalization
The stablecoin has a market cap or asset volume exceeding €5 billion.
3. 🔄 Transaction intensity
There are over 2.5 million daily transactions, representing more than €500 million in value.
4. 🛂 Gatekeeper status
An entity is deemed a gatekeeper if it fulfills the following three cumulative conditions:
Significant economic power
Control over a major access point
A dominant and lasting position
Recognized gatekeepers in the EU include: Amazon, Apple, Alphabet (Google), ByteDance (TikTok), Meta (Facebook), and Microsoft.
5. 🌍 International reach
The token is used globally, especially for payments or cross-border transfers.
6. 🏦 Interconnection with the financial system
The issuer maintains direct or indirect links with the traditional financial system.
7. 🔗 Multiple crypto-asset activities
The issuer also offers other tokens or services related to crypto-assets, beyond the stablecoin in question.
🏛️ Who becomes your supervisory authority ?
Once classified as “significant,” the issuer comes under the supervision of the EBA, except in limited cases.
Special case : If the stablecoin is denominated in a non-euro official currency (e.g. SEK for Sweden), and 80% of holders or transactions are concentrated in a single country, supervision remains national (e.g. Finansinspektionen in Sweden).
⚠️ What are the additional obligations?
Being granted the status of significant stablecoin issuer comes with:
Stricter prudential requirements
Increased regulatory audits
More frequent and detailed reporting
Enhanced standards for operational resilience, cybersecurity, and transparency
🎯 Why is this status strategic?
The “significant” classification:
Targets major players in the European crypto market
Enables harmonized oversight at EU level
Protects consumers and financial stability
Prepares the ecosystem for banking-level activity volumes
📝 In summary
Criterion | Minimum Threshold |
Token holders | Over 10 million |
Market cap / assets | Over €5 billion |
Daily transactions | Over 2.5 million / day and over €500 million |
Gatekeeper status | 3 cumulative conditions |
Geographic reach | International |
Financial interconnection | Yes |
Service multiplicity | Yes |
If you are a stablecoin issuer approaching these thresholds, it's crucial to anticipate the implications of EBA supervision. A sound legal, accounting, and operational strategy will be essential to comply with the heightened requirements of significant importance status.
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