Aave Labs Urges a MiCA Framework Focused on Intermediaries
Aave Labs proposed rules centered on intermediaries, self-custody and tokenized-property clarity; the submission is advocacy, not adopted EU policy.

On September 30, 2026, Aave Labs published its response to the European Commission’s MiCA review. It recommended applying obligations to identifiable intermediaries that exercise ongoing discretion rather than to open-source software, protecting self-custody, distinguishing borrower-paid lending returns and staking rewards from issuer- or service-provider-paid stablecoin interest, and allowing euro stablecoins to compete under risk-sensitive reserve rules.
The submission also asked for clearer property-law and conflict-of-law treatment for tokenized assets. These are Aave Labs’ policy proposals, not European Commission endorsement, a change to EU law or an implemented regulatory framework. The document does not establish how the Commission will respond or what final rules, if any, will follow.