Circle, Hyperliquid lobby to rewrite MiCA

Circle and Hyperliquid's policy arm have both filed comments into the European Commission's MiCA review, each asking Brussels to move their product out from under rules they say don't fit it. Circle wants the 30%+ bank-deposit reserve floor for e-money tokens dropped. Hyperliquid's policy center wants perpetual futures carved out of MiCA entirely and routed to MiFID II instead.

The reserve floor and the perps gap

MiCA currently forces euro-denominated stablecoin issuers to hold a minimum share of reserves as bank deposits, a rule meant to backstop redemptions but one Circle says concentrates risk in a handful of banks. Perpetual futures, meanwhile, were never cleanly addressed in MiCA's original text, leaving platforms like Hyperliquid operating in a gap that national regulators have started to notice.

• MiCA requires stablecoin issuers to hold at least 30% of reserves as bank deposits, per the EU regulation's text cited in filings.
• The European Commission opened its formal MiCA review process in 2026, with comment windows open to industry groups.
• Circle has flagged bank concentration risk tied to the deposit floor in prior public statements on reserve composition.
• Hyperliquid's policy center argues perps resemble derivatives products already governed under MiFID II, not payment tokens under MiCA.

Two companies, one playbook

The default read treats this as routine lobbying, two firms asking for lighter rules. The filings show something more specific: both are trying to pick which regulatory regime applies to them before the Commission finalizes it.

That choice matters more than the headline compliance cost.

MiFID II treats derivatives venues as trading infrastructure, with disclosure and conduct rules built for professional counterparties. MiCA treats stablecoins as payment instruments, with reserve rules built around retail redemption risk.

Landing in the wrong bucket means different capital requirements, different reporting, and different access to EU banking rails.

Circle's ask is narrower but higher-stakes: a reserve rule redesign.

Circle isn't asking for less oversight. It's asking Brussels to redefine what a backstop reserve looks like, since a 30%+ bank-deposit requirement during a banking stress event could turn a liquidity rule into a liquidity risk. That's a structural argument, not a compliance complaint.

Hyperliquid's ask is more existential for its EU footprint: get perps out of MiCA's language before the review closes that gap on its own terms, likely in a way that treats perps as unregistered payment-adjacent products rather than as regulated derivatives.

What the review timeline looks like

The Commission's review process runs through public comment periods before any legislative text moves, giving both companies months to shape the outcome before enforcement catches up. Neither filing guarantees a rule change. But both show which companies think the current MiCA text, as written, is a liability they'd rather fix in Brussels than defend in court.

Signals that confirm or break the read

Watch whether the Commission's review draft, expected later in the cycle, addresses perpetual futures by name or leaves the gap for national regulators to fill case by case.

Watch whether Circle's reserve floor language survives unchanged, which would signal the Commission prioritizes retail protection over issuer concentration risk.

Watch which national regulators move first on perps enforcement during the comment window, since that pace will reveal whether Hyperliquid's filing was pre-emptive or reactive.

• The Commission's MiCA review draft text, expected to address or omit perpetual futures explicitly.
• Whether Circle's 30%+ bank-deposit floor language changes or holds in any revised proposal.
• Any national regulator enforcement action against perps platforms before the review closes.