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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.

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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.

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