Overview
- The ECB’s working paper, published Friday, analyzes governance in Aave, MakerDAO, Uniswap and Ampleforth and finds control concentrated in a small group.
- Across the four protocols, the top 100 holders control more than 80% of governance tokens, with around half or more of those holdings tied to protocol treasuries or centralized exchanges.
- Voting power is even tighter than ownership as key decisions rest with a handful of delegates whose real identities are often unclear, and in Ampleforth the top 20 proxy voters hold about 96% of delegated votes.
- The paper warns these patterns could disqualify protocols from MiCA’s carve‑out for services that are fully decentralized, which may force authorization and compliance as the July 2026 deadline nears.
- Large token stakes held by exchanges, including Binance, and by project-linked wallets provide the “regulatory anchor points” supervisors say they can use to identify accountable actors.