From Bank-Issued Stablecoins to Supervisory Infrastructure: A Pan-European Oversight Layer Model Under MiCA

The rapid adoption of bank-issued stablecoins under the European Union’s Markets in Crypto-Assets (MiCA) framework introduces a systemic supervisory challenge: how can regulators, central banks, and EU-level authorities achieve continuous, scalable oversight without reliance on fragmented reporting, delayed audits, or issuer-controlled disclosures? This paper addresses this gap by framing compliance not as a periodic verification process, but as an infrastructure-level function.The proposed approach describes a neutral, read-only, and cryptographically verifiable validation layer designed for supervisory deployment across multiple stablecoin issuers, blockchain networks, and jurisdictions. Without assuming custody, execution authority, or market intervention capabilities, the framework enables real-time observability of stability, reserve linkage, and policy-relevant state changes. By externalizing compliance verification from individual issuers to an EU-level supervisory infrastructure component, the model supports scalable MiCA enforcement while preserving market neutrality and institutional independence. This architecture supports MiCA’s evolution from a purely regulatory instrument into a continuously enforceable supervisory system aligned with cross-border financial oversight requirements.