What happened
- Specific facts/numbers: A CEPR Policy Insight published on 7 September 2026 says Circle issues USDC from both the US and a French subsidiary through the same smart contract, and proposes automatic circuit breakers, fees and gates when outflows cross a set threshold, mirroring an OCC-proposed 10% rule for US issuers.
- Institutions involved: The proposal comes from CEPR researchers Edoardo D. Martino, Eric Monnet and Enrico Perotti; it discusses Circle and USDC, the European Commission, the ECB, the OCC, and the EU’s MiCAR framework.
- Regulatory/technical context: The issue is “multi-issuance,” where an EU and non-EU entity issue technically identical, fully fungible e-money tokens with the same redemption rights; the EBA has separately documented this as a MiCAR question, and MiCAR redemption-plan guidelines for ART and EMT issuers have applied since 10 February 2025.
- What to watch next: Watch whether the European Commission or EU legislators replace redemption-access restrictions with embedded run-management tools such as threshold-based fees, gates or circuit breakers; no specific next milestone was identified.
Why it matters
If EU and non-EU versions of the same dollar stablecoin remain fungible, Europe could absorb redemption pressure from runs that start outside the EU, forcing regulators to rethink how MiCAR handles cross-border stablecoin liquidity stress.
HKMA Relevance
Indirect: Hong Kong is also shaping stablecoin rules, so the EU debate over cross-border multi-issuance and redemption controls is relevant to how other international financial centers, including Hong Kong, assess offshore stablecoin run risk.