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ECB Paper Finds DeFi Governance Highly Concentrated, Putting MiCA Exemption at Risk

EU regulators now have clear targets in DeFi governance that could trigger full MiCA oversight.

Overview

  • The ECB staff working paper, released Friday, warns that many high-profile DeFi protocols may not qualify for MiCA’s “fully decentralised” exemption.
  • Across Aave, MakerDAO, Ampleforth and Uniswap, the top 100 wallets hold more than 80% of governance tokens, showing tight control.
  • Voting power is even more concentrated, with opaque delegates dominating ballots and Ampleforth’s top 20 controlling about 96% of proxy votes.
  • The researchers tie large stakes to protocol treasuries and centralized exchanges such as Binance, creating “regulatory anchor points” for accountability.
  • If supervisors take a narrow view as July 2026 nears, DAOs could face EU licensing, capital and reporting rules, though member-state enforcement is still taking shape.