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Circle Internet Financial Europe SAS
EURC
White Paper
(Articles 51 to 53 of MiCA regulation)
This white paper was notified to the Autorité de contrôle prudentiel et de résolution on May 31st, 2024, and amended on September 12th, 2024
and December 24th, 2025.
N
FIELD
CONTENTS
I.00
Table of contents
I.01 – Date of notification
I.02 – Statement in accordance with Article 51(3) of Regul ation (EU) 2023/1114
I.03 – Compliance statement in accor dance with Article 51(5) of Regulation (EU) 20 23/1114
I.04 – Warning in acc ordance wit h Article 5 1(4), point s (a) and (b) of Regula tion (EU) 20 23/1114
SUMMARY
I.05 – Warning in acc ordance wit h Article 5 1(6), second subparagra ph of Regula tion (EU) 20 23/1114
I.06 – Characteristics of the cry pto-asset
I.07 – Right of redemption
I.08 – Key information about the of fer and/ or admission t o trading
PART A - INFORMATION ABOUT THE ISS UER OF THE E-MONEY TOKEN
A.1 – Statutory name
A.2 - Trading name
A.3 – Legal form
A.4 – Registered address
A.5 – Head office
A.6 – Registration date
A.7 – Legal entity identifier
A.8 – Another identifier re quired pursuant to app licable law
A.9 – Contact telephone number
A.10 – E-mail address
A.11 – Response time (days)
A.12 – Parent company
A.13 – Members of the manag ement body
A.14 – Business activity
A.15 – Parent company business a ctivity
A.16 – Conflicts of interest disclosure
A.17 – Issuance of other crypto-assets
A.18 – Activities related t o other crypto-assets
A.19 – Connection between the i ssuer and the entity running the DLT
A.20 – Description of the con nection between the is suer and the entity ru nning the DLT
A.21 – Newly established
A.22 – Financial condition over the past three ye ars
A.23 – Financial condition since registration
A.24 – Exemption from authorisati on
A.25 – E-money Token authorisat ion
A.26 – Authorisation authori ty
A.27 – Persons other than the i ssuer offering to the public or seeking a dmission to trading of the e-
money token in acco rdance with Arti cle 51(1), secon d subparagraph of Regulation (EU) 2023/1114
A.28 – Persons other than the i ssuer offering to the public or seeking a dmission to trading of the e-
money token in acco rdance with Arti cle 51(1), secon d subparagraph of Regulation (EU) 2023/1114
A.29 - Reason for offering to the public or seeki ng admission to tradin g of the e-money token by
persons referred to in Article 51(1), second subparagraph of Regulation (EU) 2023/1114
PART B - INFORMATION ABOUT THE E-MONEY TOKEN
B.1 – Name
B.2 – Abbreviation
B.3 – Details of all natur al or legal persons involved in design and development
A DESCRIPTION OF THE CHARACTERISTICS OF THE E-MONEY TOKEN, INCLUDING THE DATA
NECESSARY FOR CLASSIFICATION OF THE CRYPTO-ASSET WHITE PAPER IN THE REGISTER
REFERRED TO IN ARTICLE 109, AS SPECIFIED IN ACCORDANCE WITH PARAGRAPH 8 OF THAT
ARTICLE
B.4 – Type of white paper
B.5 – The type of submission
B.6 – Crypto-assets characteristics
B.7 – Website of t he issuer
B.8 – Starting date of offer to the public or admis sion to trading
B.9 – Publication date
B.10 – Any other services prov ided by the issuer
B.11 – Language or languages of the white paper
B.12 – Digital token identif ier code used to uniq uely identify the cr ypto-asset or each of the several crypto
assets to which the white paper relates, where available
B.13 – Functionally fungibl e group digital Toke n Identifier, where av ailable
B.14 – Personal data flag
B.15 – LEI eligibility
B.16 – Home member state
B.17 – Host member states
PART C - INFORMATION ABOUT THE O FFER TO THE PUBLIC OF THE E-MONEY TOKEN OR ITS
ADMISSION TO TRADING
C.1 – Public offering or tr ading
C.2 – Number of units
C.3 – Trading platforms
C.4 – Trading platforms Market I dentifier Code (MIC)
C.5 – Applicable law
C.6 – Competent court
PART D - INFORMATION ON THE RIGHT S AND OBLIGATIONS ATTACHE D TO E-MONEY TOKENS
D.1 – Holder’s rights and o bligations
D.2 – Conditions of modifica tions of rights and o bligations
D.3 – Description of the ri ghts of the holders
D.4 – Rights in implementatio n of recovery plan
D.5 – Rights in implementatio n of redemption plan
D.6 – Complaint submission con tact
D.7 – Complaints handling pr ocedures
D.8 – Dispute resolution mech anism
D.9 – Token value protection schemes
D.10 – Token value protection schemes description
D.11 – Compensation schemes
D.12 – Compensation schemes descri ption
D.13 – Applicable law
D.14 – Competent court
PART E - INFORMATION ON THE UNDER LYING TECHNOLOGY
E.1 – Distributed ledger te chnology
E.2 – Protocols and technica l standards
E.3 – Technology used
E.4 – Purchaser’s technical requirements
E.5 – Consensus mechanism
E.6 – Incentive mechanisms and applicable fe es
E.7 – Use of distributed le dger technology
E.8 – DLT functionality desc ription
E.9 – Audit
E.10 – Audit outcome
PART F - INFORMATION ON THE RISKS
F.1 – Issuer-related risks
F.2 – Token-related risks
F.3 – Technology-related risks
F.4 – Mitigation measure s
PART G - INFORMATION ON THE SUSTA INABILITY INDICATORS IN RELATIO N TO ADVERSE IMPACT
ON THE CLIMATE AND OT HER ENVIRONMENT-RELATED ADVERSE IMPACTS
G.1 – Adverse impacts on cli mate and other environmen t-related adverse impacts
I.01
Date of notification
This white paper was notified to the Autorité de contrôle prudentiel et de résolution on November 26th, 2025.
I.02
Statement in
accordance with
Article 51(3) of
Regulation (EU)
2023/1114
This crypto asset white paper has not been app roved by any competent au thority in any Member Stat e of the
European Union. The issu er of the crypto-asset is solely responsible for the content of this White Paper.
I.03
Statement in
accordance with
Article 51(5) of
Regulation (EU)
2023/1114
This crypto-asset white paper complies with Title IV of Regulation (EU) 2023/1114 of the European Parliament
and of the Council and to the best of the knowledge of the management body, the information presented in the
crypto-asset white paper is fair, clea r, and not misleading and the crypto-asset white paper makes no
omission likely to affect its import.
I.04
Warning in
accordance with
Article 51(4),
points
(a) and (b) of
Regulation (EU)
2023/1114
The e-money token is no t covered by the investor compensat ion schemes under D irective 97/9/EC of the
European Parliament and o f the Council or the d eposit guarantee schemes under Directive 2014/49/EU of the
European Parliament and o f the Council.
SUMMARY
I.05
Warning in
accordance with
Article 51(6),
second
subparagraph of
Regulation (EU)
2023/1114
Warning
This summary should be rea d as an introduction to the crypto-asset white paper. The prospective holder
should base any decision to purchase this e-money token o n the content of the crypto-asset white paper as a
whole and not on this summary alone.
The offer to the publi c of this crypto asset does not constitute a n offer or solicitat ion to purchase finan cial
instruments and any suc h offer or solicitation can be made only by means of a prospectus or oth er offer
documents pursuant to the applicable nat ional law.
This crypto-asset white paper does not constitute a pr ospectus as referred to in Regulation (EU) 2017/1129 of
the European Parliament and of the Cou ncil or any other offer document pursuan t to European Union or
national law.
I.06
Characteristics
of the crypto-
asset
EURC is an e-money token ("EMT"), available on public blockchain networks. EURC provides a faster, safer,
and more efficient way to send, spend, and exchange money around the world.
For every EURC issued by Ci rcle SAS and remaining i n circulation, Circl e SAS will hold eithe r one euro
("EUR") or an equivalent amount of EUR-denominated assets on behalf of holders, in order to facilitate the
frictionless movement of the e-money tokens, utilizing bl ockchain technology. As a fully r eserved e-money
token, EURC is backed by an equivalen t amount of euro-denominated assets held by Circle SAS and
redeemable 1:1 for euros.
I.07
Right of
redemption
The holders of this e-money token have a righ t of redemption at any time and a t par value. Thi s applies to
holders of EURC globally. Conditions and processes for redemption of EURC are detail ed in our Redemption
Policy available on Circle’s website (the "Website").
I.08
Key information
about the offer
and/ or
admission to
trading
EURC is only available for issuance through the Circle Mint service and it is accessible only to institutions
located in supported jurisd ictions. For a complete list of currently supporte d jurisdictions, please cons ult our
Website. EURC is listed across different regulated crypto-asset service providers and Circle SAS intends to
seek its admission to trading on future MiCA-compliant trading platforms.
PART A - INFORMATION ABOUT THE ISSUER OF THE E-MONEY TOKEN
A.1
Statutory name
Circle Internet Financ ial Europe SAS (“Circle SAS”)
A.2
Trading name
Circle France
A.3
Legal form
Not applicable as LEI is provided in A.7
A.4
Registered
address
Not applicable as LEI is provided in A.7
A.5
Head office
Not applicable as LEI is provided in A.7
A.6
Registration date
2023-07-10
A.7
Legal entity
identifier
969500OYUDADGZKCR583
A.8
Another
identifier
required
pursuant to
applicable law
Not applicable as LEI is provided in A.7
A.9
Contact
telephone
+33 (1) 59000130
number
A.10
E-mail address
EEA-Customer-Support@circle.com
A.11
Response time
(days)
7
A.12
Parent company
Not applicable as LEI is provided in A.7
A.13
Members of the
management body
Identity
Business Address
Function
Mrs. Coralie
Billmann
4 RUE DE MARIVAUX, 75002
PARIS – France
Président (President)
Mr. Michel Vaugiac
4 RUE DE MARIVAUX, 75002
PARIS - FRANCE
Directeur Général
(General Manager)
A.14
Business activity
Circle SAS is a Digital Asset Services Provide r registered with the AMF under number E2024-111, authorised
to provide digital assets custody and trading o f digital assets against other digital assets since April 15th, 2024.
Circle SAS is also an El ectronic Money Institu tion registered with the ACPR under number 17788, and
provides e-money token services.
A.15
Parent company
business activity
Circle Internet Group, Inc. is the holding company for the Circle group of companies. Its shares have been
listed on the New York Stock Exchange since June 5th, 2025.
A.16
Conflicts of
interest disclosure
We frequentl y engage wit h a wide va riety of bl ockchain an d digital asset indus try partici pants, as w ell as
startups and growth companies, and maintain relationships with a si gnificant number of crypto-asset projects,
developers, and investors. These transa ctions and relationships could create potential conflicts of interest in
management decisions that we make. For instance, cert ain of our offi cers, directors, and employees ar e active
investors in crypto-asset projects and other growth companies themselves, and may make investment
decisions that favor projects in which they have personally invested. Many of our large shareholders also make
investments in these pro jects.
A.17
Issuance
True
of other
crypto-
assets
A.18
Activities related
to other crypto-
assets
True
A.19
Connection
between the
issuer and the
entity running the
DLT
True
A.20
Description of the
connection
between the
issuer and the
entity running the
DLT
Circle SAS offers EURC on 5 b lockchains: Avalanche, Base, Ethereum, Stellar, and Solana. Circle SAS wi ll
likely add additional blockcha in support in the future and update the relevant sections of the White P aper
accordingly.
For each of these block chains, Circle has en tered into agreements wi th the blockchain ent ity or foundation,
where it exists, responsible for its adoption, by which Circle agrees to design and deploy EU RC on blockchain
networks, to make it available on the Circle Mi nt application, and to offer support to Cir cle clients accordi ngly.
Circle, for regulator y reasons (including transaction monitorin g), and as part of its commitment to support the
ecosystem, runs a node on each of the supported blockchains.
It is common practice for the relevant blockc hain foundation to support Circle's technical dev elopment efforts
through a one-off financial compensatory payment.
A.21
Newly established
True
A.22
Financial
condition for the
past three years
Not applicable
A.23
Financial condition
since registration
Circle SAS was created on June 30th, 2023.
Between June 30th, 2023, and July 1st, 2024, Ci rcle SAS did not engage in any commercial activ ities. The
company was formally incorporated on July 10th, 2023, but its oper ational activities, including the issuance of
EURC, commenced on July 1st, 2 024, afte r the completion of the necessary regulatory ap provals.
Circle SAS started its a ctivities of issuan ce of EURC on July 1st, 20 24. The share capital of Circle SAS as of
September 30th, 2025 corre sponds to €159,000,000.00. In FY2024, Circle SAS r eported a tu rnover (Net
Banking Income) equal to €3,300,119. As of December 31st, 2024, Circle SAS r eported corporate cash of
€17,871,528 and net assets of €26,309,821.
A.24
Exemption from
authorisation
False
A.25
E-money token
authorisation
Circle SAS is a licens ed Electronic Money Inst itution under n°73715 8 and a registered Dig ital Assets Services
Provider in France unde r n°E2024-111.
A.26
Authorisation
authority
French Autorité de Contrôle Prudentiel et de Résolution (ACPR)
A.27
Persons other
than the issuer
offering to the
public or
seeking
admission to
trading of the e-
money token in
accordance with
Article 51(1),
Not applicable.
second
subparagraph,
of Regulation
(EU) 2023/1114
A.28
Persons other
than the issuer
offering to the
public or
seeking
admission to
trading of the e-
money token in
accordance with
Article 51(1),
second
subparagraph,
of Regulation
(EU) 2023/1114
Not applicable.
A.29
Reason for
offering to the
public or seeking
admission to
trading of the e-
money token by
persons referred
to in Article 51(1),
second
subparagraph, of
Not applicable.
Regulation (EU)
2023/1114
PART B - INFORMATION ABOUT THE E-MONEY TOKEN
B.1
Name
Not applicable as a DTI is provided in fie ld B.12
B.2
Abbreviation
Not applicable as a DTI is provided in fie ld B.12
B.3
Details of all
natural or legal
persons involved
in design and
development
Identity
Business Address
Circle SAS
4 Rue de Marivaux, 75002 Paris, FRANCE
Circle Internet Financ ial, LLC (“Circle LLC”) (as
former EURC issuer)
1 Lincoln St, Ste 31-113 Boston, MA, 02111, USA
A DESCRIPTION OF THE CHARACTERISTICS OF THE E-MONEY TOKEN, INCLUDING THE DATA NECESSARY FOR
CLASSIFICATION OF THE CRYPTO-ASSET WHITE PAPER IN THE REGISTER REFERRED TO IN ARTICLE 109, AS SPECIFIED IN
ACCORDANCE WITH PARAGRAPH 8 OF THAT ARTICLE
B.4
Type of white
paper
EMTW
B.5
The type of
submission
MODI
B.6
Crypto-asset
characteristics
EURC is defined as an e-money t oken pursuant to Article 3.1(7) of MiCA.
As of the date of this White Paper, EURC does not constitute a “significant e-money token” as defin ed
by Article 56 of MiCA.
EURC is a digital token pegged to the EUR and was first issued by Circl e LLC in June 2022. Fro m July 1st,
2024, Circle LLC ceased issuing EURC, and Circle SAS became the sole issuer of EURC.
EURC is fully backed by an equivalent amount of EUR-denominated assets held by Circle SAS with regulated
financial institutions in segregated accounts sep arate from Circle SAS’s corporate funds, on b ehalf of, and for
the benefit of, EURC holders (the "Segregated Accounts"). This means that for every EURC issued by Circle
SAS and remaining in cir culation, Circle SAS ho lds on behalf of hol ders either one EUR or an equivalent
amount of EUR-denominated assets in its Segregated Accounts (the "EURC Reserves").
The EURC Reserves are indepe ndently reviewed by l eading accounting fi rms, providing monthly c onfirmation
that they match or exceed the EURC in circulation. EURC is not designed to create return s for holders,
increase in value, or othe rwise accrue financial benefit to EURC holders.
B.7
Website of the
issuer
Circle website (the "Websi te")
B.8
Starting date of
offer to the
public or
admission to
trading
July 1st, 2024
B.9
Publication date
May 31st, 2024 and amended on September 12th, 2024 and December 24th, 2025.
B.10
Any other services
provided by the
issuer
Circle SAS is a registe red Digital Assets Serv ices Provider in Franc e under n°E2024-111. It provides digital
assets custody and trading of digital assets against other digital assets.
B.11
Language or
English
languages of the
white paper
B.12
Digital token
identifier code
used to uniquely
identify the
crypto-asset or
each of the
several crypto
assets to which
the white paper
relates, where
available
Blockchain
DTI Code
Avalanche
FJM594L0V
Base
T1J8XQBSD
Ethereum
FJM594L0V
Solana
FZQ4WZNHC
Stellar
FMXXP963M
B.13
Functionally
fungible group
digital token
identifier, where
available
13XTMPZT3
B.14
Personal data flag
True
B.15
LEI eligibility
True
B.16
Home Member
State
France
B.17
Host Member
States
Circle SAS license to issue, distribute and redeem electronic money is passported in the following countries:
Austria
Belgium
Bulgaria
Cyprus
Czech
Germany
Denmark
Estonia
Spain
Finland
Greece
Croatia
Hungary
Ireland
Iceland
Italy
Liechtenstein
Lithuania
Luxembourg
Latvia
Malta
Netherlands
Norway
Poland
Portugal
Romania
Sweden
Slovenia
Slovakia
PART C - INFORMATION ABOUT THE OFFER TO THE PUBLIC OF THE E-MONEY TOKEN OR ITS ADMISSION TO TRADING
C.1
Public offering
or trading
OTPC
C.2
Number of units
301734209.31
C.3
Trading platforms
name
EURC is supported by major g lobal regulated digital asset services providers opera ting in the EEA and ou tside
the EEA, including for example Coinbase, Bitsta mp, Bitvavo, Kraken and ZBX. Circle SAS inte nds to maintain
these listings as long as doing so remains compliant with Applicable Laws, and will continue to seek admission
to trading for EURC across future MiCA-compliant trading platforms.
C.4
Trading
platforms
market identifier
code (MIC)
EURC is listed on numerous trading platforms, including (for those having an MIC):
Bitstamp: BESA
Bitvavo: VAVO
ZBX: ZBXE
Kraken: PESL
C.5
Applicable law
France
C.6
Competent court
Any dispute with the of fer to the public of EURC in the EEA shall be br ought exclusively i n the Commercial
courts of Paris, France except where prohibited by the laws of France (the "Applicable Laws")
PART D - INFORMATION ON THE RIGHTS AND OBLIGATIONS ATTACHED TO E-MONEY TOKENS
D.1
Holder’s rights
and
obligations
EURC issued by Circle SAS is an EMT subject to M iCA regulation and App licable Laws. Under thes e
regulations, EMT means a type of cryp to-asset that purports to maintain a stable val ue by referencing the value
of one official currency.
Holding EURC tokens does n ot provide rights to EURC holders other than th ose rights provided wi thin this
White Paper, as well as under MiCA r egulation a nd Applicab le Laws.
EURC holders understand th at sending EURC to another address automatically transfers and assigns to the
owner of that address, and any subsequent EURC holder, the right to r edeem EURC for EUR funds so long as
the EURC Holder is eligible to.
EURC transactions are not reversible. Once EURC hold ers send EURC to an address, EURC holders accept
the risk that they may lose access to, an d any claim on, that EURC indefinitely or perman ently. For example, (i)
an address may have been entered incorrect ly and the true owner of the addr ess may never be discov ered, (ii)
EURC holders may not have (o r subsequently lose) the private key associ ated with such address, (iii) an
address may belong to an entity that will not return the EURC, or (iv) an address belongs to an entity that may
return the EURC but first requires action on their pa rt, such as verification of EURC holders’ identity. For the
avoidance of doubt, Circle SAS does not have to track, verify or determine the provenance of EURC balances
for EURC holders outside of Circle Mint, including any form of security int erests claimed thereon unless
otherwise stated in the Applicable Laws.
EURC holders have a legal claim against Circl e SAS as the sole issuer of EURC. These holders are entitled to
request redemption of their EURC from Circle S AS. Such redemption will be made at any tim e and at par
value, subject to complying with AML requirem ents.
EURC holders shall have the right to request r edemption of their EURC fro m Circle SAS with respect t o any
EURC issued on a blockcha in supported by Circl e SAS.
While Circl e SAS may hol d the EURC Res erves in in terest-bearing accounts or other yield-generating
instruments, EURC h olders acknowledge that they are not entitled to any interest or other re turns earned on
such funds. EURC does not itself gener ate any in terest or return for EURC holders and only represents your
right to redeem EURC for an equivalent am ount of EUR as provided in the present W hite Paper.
As required by its li cense, Circle SAS will validate and process redemptions for EURC holde rs that successfully
pass prior Anti-Money Laundering ("AML") checks, which include:
● Collection of releva nt Know Your Customer documents;
● Verification of iden tity and screening ve rsus international s anctions lists;
● Verification of the v alidity of the trans action by which the EURC wa s acquired;
● Verification of bank details; and
● Circle’s Compliance de partment validation.
More information on the redemption of EURC is provi ded in the Circ le SAS Redemption Policy available on
Circle’s Website.
The holding of EURC will not result in: (i) the creation or imposi tion of any lien upo n any property, asset, or
revenue of Circle SAS or (ii) the creation of any sha reholding or ownership interest in Circle SAS, Circle LLC,
or any of their respective affil iates.
By holding, using, or accessing EURC, EURC holders further represent and warrant that:
● they are holding and using EURC in comp liance with this White Paper and Applicable Laws;
● they are at least 18 years old, are not a Res tricted Person (as defined in the Redemption Policy), are
not owned or controlled by a Restricted Person, and are not hol ding EURC on behalf of a Restricted
Person; and
● they will not be using EURC for any illegal activity including, but n ot limited to, illegal gambling, money
laundering, fraud, blackm ail, extortion, ransoming data, terrorism financing, other violent activities, or
any prohibited market practices. For more details, please consult Ci rcle’s Acceptable Use Policy.
EURC holders accept that Ci rcle SAS reserves the ri ght to block certain EURC addresses that it de termines, in
its sole discretion, may b e associated with illegal ac tivity or activity that oth erwise violates Circle SA S’s Terms
of Use and/or this White Paper ("Blocked Addresses"). In certain circumstances, Circle SAS may deem it
necessary to report such suspected illegal activity to relevant law enforcement agencies and EURC holders
may forfeit any rights associated with their EUR C, including the ability to r edeem EURC for EUR. Circle SAS
may also be requir ed to freeze EUR C and/or surrende r associated EUR-assets held in segregated accounts in
the event it receives a legal order from a valid gov ernment authority requiring it to do so.
EURC is also issued and redeemed in accordance wi th Circle's Stablecoin Access Den ial Policy. Circle SAS
reserves the right to block the transfer of EUR C to and from an address on chain as permitted under such
policy.
EURC holders shall hold and use EURC exclusivel y for their own account and shall in no cas e be considered
as nominees or agents of Circle SAS, unless otherwise expressly agreed in wri tten form by Circle SAS.
EURC holders are duly in formed that Circle SAS’s l iability (and its affiliates, its re spective officers, di rectors,
agents, joint venturers, employees, and suppliers) is l imited to what is expressly provided in the Applicable
Laws and the present White Paper. In particular (but without limitation), EURC holders are duly informed and
acknowledge that Circle SAS shall bear no liability with regard to i) their use of EURC ; (ii) claims or issue
concerning the cost of procurement of substitute goods and servi ces resulting from any goods, data,
information, or services purchased or obtained or messages received or t ransactions entered into involving
EURC; or (iii) unauthori sed access to or alte ration of EURC holders tr ansmissions or data in curred by the use
of EU RC.
In this respect, to the full extent permissible by App licable Laws, Circle SAS disclaims all warranties, express or
implied, including, but not limited to, implied warran ties of merchantability an d fitness for a particular purpose.
To the full extent per mi ssible by Applicable Laws, Circle SAS shall not be liable for any damages of any kind
arising from the use of EURC, including, but not limited t o direct, indirect, incidental, punitive, and
consequential damages.
D.2
Conditions of
modifications of
rights and
obligations
The rights and obliga tions associated with EURC and applicable to EURC holders are availab le in the
Redemption Policy and Ter ms of Use available on Circle’s Website.
Circle SAS reserves the r ight to amend these rig hts and obligations from time to time, and wil l inform its
customers of such changes through amendments of this White Paper or the Redemption Policy on Circle’s
Website, or through any other channel of communication considered v alid, including on Circle’s Website.
As provided by Article 51 of MiCA regulation, any significant new f actor, any material mist ake, or any material
inaccuracy that would be capable of affecting the assessment of EURC will be described in a m odified version
of this White Paper and notified to the competent authorities and published on Circle’s Website, except when
these modifications are related to the impleme ntation by Circle SAS of its Recovery Plan or Red emption Plan
(please refer to Sections D.4 and D.5 below).
D.3
Description of
the rights of the
holders
Should it become insol vent, Circle SAS has impl emented high standards f or safe and sound fina ncial
management of its business. In a si tuation of fin ancial duress or in periods of e conomic uncertaint y, Circle SAS
has established contingency plans to prevent any impact on its act ivities, including the issuance of EURC, or
the rights of EURC holders.
Where Circle SAS is not a ble to ful fill its o bligations or in the event of in solvency, t he EURC Reserv es are duly
protected in compliance with the Applicable Laws. In particular, the funds received in exchange for issuance of
EURC are protected against any recourse by other creditors of Circle SAS, including in the event of
enforcement proceedings or insolvency proceedings against Circle SAS.
If a situation of financial duress or insolvency were to occur, Circle SAS will implement its Recovery and/o r
Redemption Plan to allo w EURC holders to exercise their redemption righ ts on EURC as further speci fied in
Sections D.4 and D.5 bel ow.
D.4
Rights in
implementation of
recovery plan
D epending on the specific circumstance(s) under which the Recovery Plan implemented by Circl e SAS in
compliance with Article 55 of MiCA might be triggered, Circle SAS may have to impose one or more specific
restrictions on the redemption of EURC.
EURC holders will be dul y informed about any su ch restrictions on Ci rcle’s Website. Customers will also be
informed via their Circle Mint Account or anothe r valid means of commu nication between Circle S AS and the
Customer. For instance, Ci rcle SAS may temp orarily impose:
● liquidity fees on redemptio ns;
● limits on the amount of EURC that can be re deemed on any working day – such limit will be set both at
aggregate levels (e.g. as a percentage of the entire amount of tokens issued) and at wallet levels;
and/or
● suspension of redemptions, as a last resort.
Example actions listed above don’t constitu te an exhaustive lis t; other actions may be taken by Circle SAS in
accordance with its Recovery Plan.
These restrictions wil l be implemented durin g periods of market stre ss and Circle SAS will work to restore
normal operating conditions – subject to regulatory requirements – in collaboration with the ACPR.
D.5
Rights in
implementation of
redemption plan
T he Redemption Plan implemented by Circle SAS in compliance with Article 55 of MiCA is an operational plan
to support the orderly redemption of EURC in circulation.
The Redemption Plan will be triggered upon a d ecision by the ACPR, if Circle SAS is unable or likely to be
unable to fulfill its obligations, includi ng in the case of insolvency, resolution, or the wit hdrawal of authorisation
of Circle SAS as an E-Money In stitution. The processes set forth in the Redemption Plan will be established
with a view to ensurin g the equitable treat ment of all EURC holders a nd the protection of t he right of
redemption attached to EURC as des cribed above.
If the ACPR triggers the implementation of the R edemption Plan, any individual claim under Sec tion D.1 above
will be suspended. Ci rcle SAS will commence the orderly redemption for all EURC holders in an equitable
manner.
As part of this process, a notice will be p ublished informing al l EURC holders about the process and timelines
to submit their redemption claim. Specifically, the notice will describe the main steps of the redemption
process, including the exact date and t ime when the redemption plan has been activated, the minimum
information necessary to file a redemption claim, where the claim should b e filed, and the time fra me within
which EURC holders are req uired to file their claim. The notice wil l also contain impo rtant information regarding
redemption conditions and technical supp ort.
Redemption requests submit ted via a redemption cl aim form will be subje ct to certain eligi bility criteria
described in the Redemption Policy, and as further specified i n the Redemption Plan notice information,
including their identity, the ir token holdings, AML/CFT c ompliance, their bank account details, and o ther
information required to f ile their redemption reque st.
D.6
Complaint
submission
contact
If you have a complaint, please first contact C ircle SAS at EEA-Customer-Support@circle.com, or visit the
Circle Support Portal.
D.7
Complaints
handling
procedures
EURC h olders can file a complaint by leaving a message at the contact number provided in Section A.9 or filing
it through the customer support email address or Circle Support Portal. Upon receiving a comp laint, the Customer
Care Team member will log the case and escalate it to a Customer Care Manager. The Customer Care Manager
is responsible for reviewing the deta ils of the complaint.
Circle SAS handles complaints submitted by i ts direct Customers or by EURC holders experiencing issues with
the EURC redemption process for their EURC. However, complaints relating to the purchase of EURC from third
parties or to the loss of tokens held in self-custody or custodied with third part ies fall outside the scope of Circle
SAS’s Customer Care support.
If appropriate, all details and data will be compiled and es calated to the Legal Department. When such an
escalation occurs, the Legal Department is responsi ble for investigating the case and working towards closure.
If escalated to the Legal Department, all communications with the customer will be instructed by the Legal
Department.
The Cust omer Care Depart ment wil l re main ac tively involved in any customer complaint or service requirement
and serves as a first line of support and an advocate f or customers prior to any internal escalation.
1st level
2nd level escalations
3rd level escalations
Customer Complaints
Customer Care
Customer Care
Manager
Legal Department
Complaints For Fraud
Customer Care
Customer Care
Manager
Legal Department
Technical Issues
Customer Care
Engineer / Technical
Operations
Engineer Manager
Claim Management
Customer Care
Customer Care
Manager
Legal Department
D.8
Dispute resolution
mechanism
In the event that Circle SAS’s response to the ir complaint is not satisfactory, EURC holders and customers can
refer their claim to the ACPR:
● By mail sent to the fol lowing address:
Banque de France - ACPR
TSA 50120
75035 PARIS CEDEX 01
● By electronic means, by c reating an account on the online applicat ion portal of the Banq ue de France
(https://accueil.banque-france.fr/index.html#/accueil)
D.9
Token value
protection
schemes
True
D.10
Token value
protection
schemes
description
As a MiCA compliant regula ted e-money token, EURC will be fully backed by an equivalent amount of EUR-
denominated assets held by Circle SAS with regulated financial instit utions in segregated accounts apart from
Circle SAS’s corporate f unds, on behalf of, an d for the benefit of, EURC holders.
D.11
Compensation
schemes
False
D.12
Compensation
schemes
description
Not applicable.
D.13
Applicable law
France
D.14
Competent court
Any dispute concerning the rights and obli gations of residents arising out of the us e or ownership of EURC
shall be brought exclusively to the Commercial courts of Paris, France, except where provided otherwise by
Applicable Laws.
PART E - INFORMATION ON THE UNDERLYING TECHNOLOGY
E.1
Distributed ledger
technology
Not applicable as DTI i s provided in B.13
E.2
Protocols and
technical
standards
Circle SAS supports EURC on 5 blockchains during its launch phase, in cluding Ethereum, Avalan che, Solana,
Stellar and Base ("EURC Supported Bloc kchains"). Circle SAS will likely add additional blockchain support in
the future and will update the list of EURC Supporte d Blockchains on its Website.
Circle SAS has developed its technical e-money token specification fo r deploying EURC on Ethereum-Virtual-
Machine ("EVM") compatible base layers. This specification extends the existing ERC-20 fungible token
standard with additional core functionality required for Circle SAS, for example the blocklisting feature that
allows Circle SAS to prevent specific blockchain addresses from sending and receiving EURC.
For not natively EVM compati ble networks (Solana, Stellar), Circle SAS has assessed the existin g available
Token Standards for each base layer and deploy ed EURC on the Token Standard that is best suited for Circle
SAS’s specifications a nd required function ality.
Blockchain
Token Standard
Avalanche
ERC-20
Base
ERC-20
Ethereum
ERC-20
Solana
SPL Token
Stellar
Stellar Assets
EURC is deployed using u pgradeable smart contrac t architectures via t he proxy patterns of th e Universal
Upgradeable Proxy Standar d (UUPS) – introduced via ERC-1822 – on Avalanche, Base, and Ethereum. These
implementations allow the contract logic to be mo dified without changing t he token address. Solan a and
Stellar’s native tok en standards follow th eir own upgradeable pr oxy model. The upgradeabl e smart contract
architectures include the UUPS proxy pattern, allowing contract l ogic to be updated without chang ing the token
address. Despite these additions, the contracts preserve the expected ERC-20 behaviour, such as transfer,
approve, and balance.
While EURC is available on 5 block chain networ ks ("EURC Supported Blockchains") to date, Circle will likely
add additional blockchain support in the future and will update the list of EURC Supported Blockchains on its
Website.
Circle may, based on fac tors such as transacti on volumes or compliance considerations, deci de to discontinue
support for certain EURC Supported Blockchains. In such cases, the process for exchange or redemption by
EURC holders on the affect ed blockchains w ill be published on its Website.
E.3
Technology used
EURC integrates with a range of supporting technologie s beyond its smart cont ract implementations. C ircle
provides fiat on- and off-ramp functionality, transaction monitoring, and identity verification w orkflows,
facilitating compliance-aligned integrations fo r exchanges, custodians, and fintech platform s.
On EVM-compatible networks, EURC is fully interoperable with the st andard JSON-RPC interface and
commonly used libraries such as Web3.js and Ethers.js, ensuring compatibili ty with Ethereum tooling. On non-
EVM blockchains, EURC intera cts through each chain’s native communication and SDK interfaces.
EURC metadata handling, rel evant to multiple le vels such as contract interfaces, block exp lorers, token lists
and wallet integrations, is implemented through established convent ions. On EVM blockchains, EURC
contracts expose the standard ERC-20 metadata functions. On Solana, metadata is stored on-chain through
the Metaplex Metadata Program, wh ereas on Stellar, metadata is stored off-chain through a stellar.toml file
hosted by Circle.
Because wallet integra tion is broadly supp orted, with EURC recognise d and rendered by all major Web3
wallets, these convent ions ensure consisten t user display and i nteraction across netwo rks.
E.4
Purchaser’s
technical
requirements
Circle Mint, Circle SAS’s service that allows its customers to access EURC directly from Circle SAS, is
currently only available to institutions located in supported jurisdictions. Circle Mint is subject to Circle SAS’s
Terms of Use.
The purchase of EURC on the secondary market, for exa mple, with EU-regulated trading platforms, is available
to all users of these third-party platforms. Most third-party trading and exchange services provided by regulated
crypto-asset service providers are open to retail customers as well and subject to their own compliance
requirements.
Prospective EURC holders mus t use wallets compatibl e with the blockchai ns on which EURC is nativ ely
issued.
Usage of EURC requires the EURC holders to cover netwo rk fees, which may be gas fees on Ethereum and
Layer 2s (Base) and transaction fees on other blockchains.
E.5
Consensus
mechanism
Not applicable as EURC is a token and therefore does not have a consensus mechanism. EURC runs on base
layers, which may be blo ckchains or layer-2 networks, in turn based on blockchains. Blockchains rely on
consensus mechanisms to ensure their decentralised network of nodes can reach agreement around
transaction validity and ordering.
E.6
Incentive
mechanisms
and applicable
fees
Each blockchain we supp ort has developed its own incentive mechanis ms and request fees to re alise
transactions.
Please refer to the webs ite of each of these b lockchains for more det ails on the mechanisms i n place.
As of today, Circle SAS do es not take additiona l fees on these mechani sms.
E.7
Use of
distributed
ledger
technology
False
E.8
DLT functionality
description
This field does not a pply as E.7 is FALSE
E.9
Audit
True
E.10
Audit outcome
Circle LLC, as technic al provider to Circl e SAS, is responsible f or ensuring that its smart contracts are
developed in a safe and secure manner. As such, Circle works with industr y leading security auditing firms
such as Chain Security, Kudelski, Halborn, and others, to audit every EURC smart contr act prior to launch or
upgrade.
Any identified issue s during these audits are reviewed, valida ted, assessed and remedi ated according to thei r
severity prior to launch or upgrade.
As a matter of best practi ce and policy, Circl e SAS always open-sources every EURC smart contract that it has
deployed. This enables independent security researchers to verify the contract for any security vulnerabilities.
To enable responsible disclosure, Circle operates a p ublic vulnerabili ty disclosure program a nd a private bug
bounty program via HackerOne that enables vulnerabilities to be di sclosed to Circle.
As part of Circle SAS’s b lockchain due dili gence process when it e valuates deploying EURC on new
blockchains, Circle SAS requires independent security audits to be per formed on the blockchains themselves.
As a matter of policy, a ll audit results ar e internally reviewe d, validated, assesse d, and remediated accord ing to
the severity of each finding. Any findings that m ay lead to loss of funds must be remed iated.
PART F - INFORMATION ON RISKS
F.1
Issuer-related
risks
As part of the EURC issuanc e process, Circle SAS is exposed to several ri sks:
1. Bankruptcy Risks. This is the ri sk of Circle SAS going bankrupt, which could result from the insolv ency
of Circle SAS as part of its activities, the fai lure of a bank holding Circle SAS own funds or EURC
reserves, or other systemic financial risks that c ould impact the operations and financial solvency of
Circle SAS.
2. Third-Party Risks. This is the r isk Circle SAS faces in its business relati onships with one or mor e third
parties. The ability of Circle SAS to properly carry out its activities relies on the functioning of services
provided by several third parties, such as banks providing safeguardi ng and settlement accounts. The
inability of these third-party service providers to carry out their services could affect Circle SAS’s ability
to properly issue, manage, and redeem EURC. Third parties can elect to support EU RC on their
platforms without any authorisation or approval by Circle SAS or anyone else. As a result, EURC
support on any third-party platform does not imply any endorsement by Circle SAS that such third-party
services are valid, legal, stable or otherwise appropriate. Circl e SAS is not responsible for any losses or
other issues encountered using EURC on third-party platforms.
3. Market Risks. This is the risk that EURC Reserves may i nclude assets that ar e not guaranteed to be
readily saleable (such as certain short-term financial securities). In that case, if there is an exceptionally
high demand for redemption of EURC, Circle SAS may not be able to fulfill all the rede mption request s
within the timeframe prov ided for in the Redempti on Policy.
4. Risk of Loss. This is the ri sk of loss caused by f raud, theft, misuse, neg ligence, or improper
administration of EURC or the EURC Reserves.
5. Anti-Money Laundering/Co unter-Terrorism Financing Risks ("AML/CTF"). Thi s is the risk that
crypto-asset wallets holding EURC or transactions in EURC may be used for money laundering or
terrorist financing purposes, or identified to a person known to have committed such offe nses.
6. Personal Data Risks. This is the risk that the persona l data of Circle SAS cus tomers may be leaked or
stolen due to a security breach.
7. Risks Related to Circle SAS’s Bus iness Activities and Industry. This is the risk that resu lts from
Circle SAS operating in a rapidly changing, regulatorily fragment ed, and highly competi tive industry.
8. Legal and Regulatory Risk. Circle SAS is subject to numerous laws and regulations, and may fail to
comply with such laws and regulatory requirements of the jurisdi ctions that Circle SAS operates in.
Further, Circle SAS could be subjected to inve stigations, enforcement actions, and penalties. Circle
SAS could also be subje ct to private litig ation.
9. Internal Control Risk. Any failure to develop or maintai n effective internal controls, or any di fficulties
encountered in the implementation of such controls or their improvement, could harm Circle SAS’s
business, causing Circle SAS to have to report such failures and l ead to a loss of trust in the business.
10. Environmental, Social, and Governance Risks. Circle SAS issues EURC on various p ublic
blockchains which use different consensus algorithms. Each public blockchain, depending notably on its
consensus algorithm, has certain environmental impacts. Please see Section G bel ow for sustainability
disclosures for EURC on each individual blockchain. EURC is not issued on blockchains usi ng the most
energy-intensive proof-of-work consensus mechanism, and the blockcha ins currently support ed by
Circle SAS generally us e Proof-of-Stake (or a modified vers ion of that mechanism), t he environmental
impacts of which are ve ry limited compared to P roof-of-Work. In the fut ure, enviro nmental regu lations
affecting consensus mechanisms may restrict Circle SAS’s ability to issue EURC on individual public
blockchains if their sustainability impact is consider ed too negative.
11. Outsourcing Risk. This is the r isk that Circle SAS beco mes structurally depend ent on Circle LLC for
critical services.
F.2
Token-related
risks
1. Financial Stability Risks. Since EURC is a major stablecoin th at is used by and integra ted in many
significant market infrastructures (e.g. crypto-asset trading platfor ms), a problem affecting EURC could
indirectly impact these inf rastructures and cause temporary instability.
2. Secondary Market Price Dislocati on Risk. This is the risk tha t the market value of EURC o n the
secondary market is not stable compared to the EUR. This price dislocati on could be caused by various
factors, such as under-collateralisation risk and secondary market liquidity risk (see below).
3. Risk of Under-Collateralisation. This is the risk that, du e to fraud or mismanagement (by either Circle
SAS or a third-party provider), the value of the reserve of assets backing the redeemability of EURC
becomes lower than the outstanding quantity of EURC. That risk would likely cause a price dislocation
of the market value of EURC (see above) and affect the ability of Circle SAS to redeem holders at par
or in a timely manner.
4. Liquidity Risk. This is the r isk that the EURC Reserves may include assets that are not readily
liquidated (such as certain short-term financial securities) or any tec hnical and operational issues
causing delays and liquidity risk (e.g. loss of APIs or correspondent issu es). In that case, if there is an
exceptionally high demand for redemption of EURC, Circle SAS may not be able to ful fill all the
redemption requests within the timeframe p rovided by the Redemption Policy. Such risk could also
cause a secondary market price risk (see above).
5. Scam Risks. This is the risk of loss resulting fr om a scam or fraud suffered by EURC holders from
other malicious actors. These scams include – but are not limited to – phishing on social networks or by
email, fake giveaways, identity theft of Circle SAS or it s execu tive members, creation of fake EURC
tokens, offering fake EURC airdrops, amo ng others.
6. Taxation Risks. The taxation re gime that applies to EURC purchases and sales by either individual
holders or legal entities will depend on each holder’s jurisdiction. Circle SAS cannot guarantee that
conversions of fiat currency against EURC, or conversions of other cryp to-assets against EURC, will
not incur tax consequences. In addition, EURC holders should be warned that, based on the current
provisions of MiCA, EURC could qualify both as a crypto-asset and as electroni c money. Which legal
classification prevails might vary amongst national competent author ities and will likely impact the tax
treatment of EURC transactions.
7. Legal and Regulatory Risk. This ris k stems from the fact that e-money tokens and crypt o-asset
services are unregulated in certain jurisdictions out side of the EEA. There is also a lack of regulatory
harmonisation and cohesion globally which could lead to diverging r egulatory frameworks globally
and/or an evolution of EU e-money token an d crypto-asset rules in the futur e.
F.3
Technology-
related risks
Purchasing and using EURC may also expose the holder to technological risks.
1. Blockchain Risks. One or sev eral of the blo ckchain network(s) on which EURC i s issued may be
subject to technical vulnerabilities and be exposed to at tacks that could lead to a general network
disruption, such as unexpected pauses in transactions, inabili ty to proceed with transfers of EURC,
major losses for network partici pants, or unexpect ed liquidity mov ements.
2. Smart Contract Risks. The smart co ntracts deployed by Ci rcle SAS to mint or burn EURC on the
various blockchains or to ensure the transfer of EURC (notably t o other blockchains) may be exposed
to technical vulnerabilities that could lead to losses for EU RC holders.
3. Settlement Finality or Irrevoca bility of Blockchain Transactions. Depending on the tools a nd
services providers used to initiate EURC transactions, these tr ansactions may be irreversible. Once you
send EURC to a blockchain address, you accept the risk that you may lose access t o, and any claim
on, that EURC indefinitely or permanently. For example: (i) a bl ockchain address may have been
entered incorrectly and the true owner of the address may never be discovered, (ii) you may not have
(or may subsequently lose) the privat e key associated with su ch address, (iii) a blockch ain address may
belong to an entity that will not return the EURC, or (iv) a blockchain address may belong to an entity
that may return the EURC, but first requires ac tion on your part, such as verification of your iden tity.
4. Personal Data Risks. Pursuant to the General Data Protection Regulation ("GDPR"), Circle SAS is
required to take all necessary precautions: (i) with re gard to the nature of the data collected and the
risks presented by the processing of su ch data, (ii) to preserve the security of EURC ho lders' personal
data and, (iii) in particular, to prevent such data from being distorted, damaged, or accesse d by
unauthorised third parties.
5. Unanticipated Risks. E-money tokens s uch as EURC are a relatively new and untested techn ology. In
addition to the risks included in this section, there might be other risks that cannot be foreseen.
Additional risks may a lso materialize as un anticipated variati ons or combinati ons of the risks discussed
within this section.
F.4
Mitigation
measures
Regarding the differen t risks identified in Sections F1, F2 and F3, Circle SAS implements app ropriate
measures to mitiga te these risks a nd protect its customers, as fol lows:
1. Mitigation measure s concerning issue r-related risks
Circle SAS has implemented a comprehensive Risk Manag ement and Internal Contro l Framework grounded in
the Three Lines of Defense model. The first line, comprising business and operational team s, owns and
manages risks in d ay-to-day activities. The second l ine, composed of compliance, security and risk
management functions, provides indepe ndent oversight a nd ensures polici es, controls, an d processes are
robust and effective. The third line, internal audit, cond ucts independent assessments o f the control
envi ronment. Circle SAS performs regular and proa ctive risk assessments to identify, evaluate, a nd address
evolving threats and vulnerabilities. The company enforces a permanent control system that includes regular
testing, incident tracking, and corrective action follow-ups. Ongoing training and awareness initiatives further
embed a strong risk culture across the organization, ensuri ng that staff remain vigilant and empowered to
uphold the highest standards of integrity and compliance.
Specific mitigations for each of the risks are as follows:
1.1. Bankruptcy Risks. While there is no legal prec edent, Circ le SAS's ban kruptcy shou ld have no impact on
the rights of EURC holders. If Circle SAS goes ba nkrupt, the EURC Reserves are protec ted by Applicable Law
and cannot be used to compensate Circle SAS’s other creditors. Bank accounts used by Cir cle SAS for the
EURC Reserves are safeguarde d from Circle SAS creditor s as provided by Appli cable Law. Any EURC will be
refunded to its holders as part of Circle SAS's ba nkruptcy proceedings, without the holder n ecessarily having to
file a claim for compensation.
1.2. Third-party Risks. When Cir cle SAS reli es on a thi rd party to provide se rvices that are import ant to
EURC, Circle SAS generally enters into an agreement containing specifi c clauses ensuring th at the service
provider cannot terminate the business relationship without advanced notice. Some of these agreements (such
as the agreements concerning the safeguarding accounts used to invest t he EURC Reserves) are also subject
to regulatory obligations. In addition, Circle SAS impleme nts internal procedures who se purpose is to limit
disruption in the event that an important service pr ovider terminates an agreement or becomes unable to
provide its services to Circle SAS. Finally, third part ies with whom Circle SAS contracts are subject to due
diligence procedures to ensure their financial viability and to limit any other risks of non-compliance. To further
mitigate dependency risk, Circle SAS applies a div ersification st rategy, aiming t o avoid excessive concentration
with any single banki ng, custody, or operat iona l partner. This inc ludes maintaining relationsh ips with multiple
safeguarding institutions and service providers where feasibl e, regularly assessing diversification metrics, and
establishing contingency options to ensure operational continui ty in the event of a third-party failure or service
interruption.
1.3. Market Risks. Circle SAS’s systems and procedur es are set up in a way that ensures that EURC
redemptions will occur in the timeframe set out in th e Redemption Policy, even if volatility in crypto-asset
markets causes a si gnificant incre ase in redemption requests.
1.4. Risks of Loss. The redemption right of eligi ble EURC holders remains e xercisable even if Ci rcle SAS
suffers a loss at the level of the safeguarded assets. As is required under Applicable Law, Circle SAS is well-
capitalised and funded and, as an electronic money institut ion, Circle SAS is subject to regulatory capital and
own-funds requirements. In the event tha t the loss should exceed Circle SAS’s ability to redeem the EURC
holders, the EURC Recovery Plan or the EURC Redemption Plan may be triggered.
1.5. AML/CFT Risks. Each EURC redemption r equest to Circle SAS requ ires the holder to co mply with the
laws and regulations applic able to anti-money laundering and counter-terrorist financing in the EU. Moreover, if
Circle SAS determines that EURC transactions linke d to publi c addresses are likely to be associated with
criminal offenses, Circle SAS may decide to freeze the associated EURC (temporaril y or permanently). Also, if
Circle SAS receives an i njunction from a compete nt authority to freeze EURC, Circ le SAS will comply with such
a request.
1.6. Personal Data Risks. Pursuant to the GDPR, Circle SAS is required to take all necessary preca utions
with regard to the natu re of the data and the risks presented by the processing of such da ta, to preserve the
security of EURC holders' personal data and, in particular, to pr event it from being distorted, damaged, or
accessed by unauthorised third parties.
2. Mitigation measure s concerning the token-related risks
2.1. Financial Stability Risks. EURC has been issued since 2018 and has withstood several major volatility
events and liquidity crises. Circle SAS’s internal procedures ensure that EURC can reliably be used by market
participants and market infrastructures under all market conditions.
2.2. Secondary Market Price Disloca tion Risk. Circle SAS expects t hat any disparity bet ween the EURC
price and EUR on secondary markets would be promptly resolved by market participant s (i.e. buying EURC for
less than 1 EUR on th e secondary market and redeeming it at par valu e with Circle SAS), a s any participant
will be entitled to redeem at par with Circl e SAS. Otherwise, if the p rice dislocation i s caused by an inadequ acy
of the EURC Reserves or other liquidity issues, Circle SAS will apply t he measures set out in its Recovery Plan
or Redemption Plan.
2.3. Risks of Under-Collateralisation. If the EURC Reserves become lower than the outstanding quantity of
EURC in circulation, Ci rcle SAS will apply th e measures set out in i ts Recovery Plan or Redempt ion Plan.
These plans include mea sures that could resol ve the under-collateralisation through, for example, a
strengthening of Circle SAS’s capital position.
2.4. Liquidity Risk. Circle SAS will implement a Redemption Pol icy designed to ensu re the prompt redemption
of EURC and to respond to scenarios of extreme demand for redemption in unfavor able market conditions.
Circle also looks to expand its settlement banking footprint wit h major banking partners to limit Liquidity Risk.
2.5. Scam Risks. Circle SAS canno t prevent all attempts to defraud or scams in c onnection with EURC. The
general terms and conditions relating to EURC issuance specify that Cir cle SAS is not liable for this type of
loss. From time to tim e, Circle SAS will infor m its client s of such risks through various channels.
2.6. Taxation Risks. The tax conseq uences of EURC transaction s should be assessed a t the level of each
EURC holder. It is the so le responsibility of EURC holders to address taxation risks in c onsideration of thei r
personal situation. Circle SAS does not provide, nor accept re sponsibi lity for, any legal, tax or accounting
advice. If EURC holders are unsure regarding any of the legal, tax or accounting aspects of their situation
regarding EURC, they should seek indep endent professional advice.
3. Mitigation measure s concerning techn ology-related risks
3.1. Blockchain related Risks. Whil e risks ex ist for all blockchai n networks, blockchain networks us ed by
Circle SAS to issue EURC are recognised for their high level of secur ity and have generall y withstood several
major events with out any interrup tion to their normal functionin g. Befo re launching EURC on any new
blockchain, Circle SAS conducts thorough due diligence, including blockchain-level security audits, as w ell as
the review of the history of the blockchain, the lev el of decentralisation, and the degree of resilience or activity
on the network.
Mandatory Information on principal adverse impacts on the climate
N
Field
Content
General Information
S.1
Name
Circle Internet Fi nancial Europe SAS
S.2
Relevant legal
entity identifier
969500OYUDADGZKCR583
3.2. Smart Contract Risks. To reinforce the resilience of t he smart contracts for EURC i ssuance, Circle SAS
is making the contract a ddresses linked to EUR C issuance open-source so that anyone can consult them and
alert Circle SAS in the event of a default. The code source of the smart contracts is publicly available in real
time. In addition, each smart contract relating to E URC issuance has been audited. In the event of a
modification to the source code, the smart contrac t is audited aga in to ensure tha t no potential security exploit
can be used to fraudulently use the EURC mint or burn system or to ci rcumvent its initial use by other means.
More specific inf ormation on the audits carried o ut on the EURC i s detailed in Se ction E.3.
3.3. Settlement Finality or Irrevocabil ity of Blockchain Transactions. Circ le SAS cannot prevent
blockchain transactions from being irreversible and in many cases, will not be able to mitigate this risk, not ing
that irrevocability is also a major security element of bloc kchain networks. Circle SAS will not be held liable for
this type of loss. From time to time, Circle SAS will inform its clients of such risks through various channels o f
communication.
3.4. Security Program. Circle SAS is supported by a dedicated cybersecurity team that monitors the
technology environment 24/7, impleme nts multiple layers of security defenses, and p erforms ongoing security
scanning and testing.
G – Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts
N
Field
Content
General Information
S.3
Name of the
crypto-asset
EURC
S.4
Consensus
Mechanism
Not applicable as EURC is a token and therefor e does not have a consensu s mechanism. EURC runs on base layers,
which may be bloc kchains or layer-2 networks, in turn based on blockchains. Blockchains rely on consensus
mechanisms to ensure t heir decentralise d network of nodes can reach agreement arou nd transaction validity and
ordering.
S.5
Incentive
Mechanisms and
Applicable Fees
Each blockchain we support has developed its own incentive mechanisms and request fees to realise transactions.
Please refer to the website of each of these blockchains for more details on the mechanisms in place.
As of today, Circle SAS does not take additional fees on these mechanisms.
S.6
Beginning of the
period to which
the disclosure
relates
2024-10-17
S.7
End of the period
to which the
disclosure
relates
2025-10-16
Mandatory key indicator on energy consumption
N
Field
Content
General Information
S.8
Energy
consumption
Base layer
kWh per calendar year
Avalanche
6.48838
Base
12.12053
Ethereum
725.75169
Solana
245.55582
Stellar
595.02527
Total
1,584.94169
Sources and methodologies
S.9
Energy
consumption
sources and
methodologies
Data provided by the MiCA Cry pto Alliance as a thir d party, with no deviati ons from the calculation guidance of
Commission Delegated Regul ation (EU) 2025/42 2, Article 6(5). As the base layers are decentralised ne tworks,
estimates on individual node power d raw are used.
Full methodology available at: www.micacrypto alliance.com/methodol ogies
Supplementary Information on the principal adverse impacts on the climate and other environment-related
adverse impacts of the consensus mechanism
N
Field
Content
Supplementary key indicators on energy and GHG emissions
S.10
Renewable
energy
consumption
Base layer
Percentage (decimal)
Avalanche
35.3318926442%
Base
39.0326707634%
Ethereum
35.4272282688%
Solana
40.5646569227%
Stellar
38.8450452475%
Total
37.3706293169%
S.11
Energy intensity
Base layer
kWh per transaction
Avalanche
0.0001420059
Base
0.0000011576
Ethereum
0.0066300793
Solana
0.0000267525
Stellar
0.0000309041
Total
0.0000406217
S.12
Scope 1 DLT GHG
emissions
– controlled
Base layer
t CO2eq per calendar year
Avalanche
0
Base
0
Ethereum
0
Solana
0
Stellar
0
Total
0
S.13
Scope 2 DLT GHG
emissions
– purchased
Base layer
t CO2eq per calendar year
Avalanche
0.01135
Base
0.01822
Ethereum
1.10959
Solana
0.08378
Stellar
0.22336
Total
1.44630
S.14
GHG intensity
Base layer
kg CO2eq per transaction
Avalanche
0.0002485118
Base
0.0000017400
Ethereum
0.0101366509
Solana
0.0000091274
Stellar
0.0000116006
Total
0.0000121555
Sources and methodologies
S.15
Key energy
sources and
methodologies
Data provided by the MiCA Cry pto Alliance as a thir d party, with no deviati ons from the calculation guidance of
Commission Delegated Regul ation (EU) 2025/42 2, Article 6(5).
Full methodology available at: www.micacrypto alliance.com/methodol ogies
S.16
Key GHG sources
and
methodologies
Data provided by the MiCA Cry pto Alliance as a thir d party, with no deviati ons from the calculation guidance of
Commission Delegated Regul ation (EU) 2025/42 2, Article 6(5).
Full methodology available at: www.micacrypto alliance.com/methodol ogies