1
Circle Internet Financial Europe SAS
USDC
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 12
th
, 2024
and December 16
th
, 2025.
N
FIELD
CONTENTS
I.00
Table of contents
I.01 – Date of notification
I.02 – Statement in accordance with Article 51(3) of Regulation (EU) 2023/1114
I.03 – Compliance statement in accordance with Article 51(5) of Regulation (EU) 2023/1114
I.04 – Warning in accordance with Article 51(4), points (a) and (b) of Regulation (EU) 2023/1114
SUMMARY
I.05 – Warning in accordance with Article 51(6), second subparagraph of Regulation (EU) 2023/1114
I.06 – Characteristics of the crypto-asset
I.07 – Right of redemption
I.08 – Key information about the offer and/ or admission to trading
PART A - INFORMATION ABOUT THE ISSUER 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 required pursuant to applicable 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 management body
A.14 – Business activity
A.15 – Parent company business activity
A.16 – Conflicts of interest disclosure
A.17 – Issuance of other crypto-assets
A.18 – Activities related to other crypto-assets
A.19 – Connection between the issuer and the entity running the DLT
A.21 – Newly established
A.22 – Financial condition over the past three years
A.23 – Financial condition since registration
A.24 – Exemption from authorisation
A.25 – E-money Token authorisation
A.26 – Authorisation authority
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), 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
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 Regulation (EU) 2023/1114
PART B - INFORMATION ABOUT THE E-MONEY TOKEN
B.1 – Name
B.2 – Abbreviation
B.3 – Details of all natural 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 the issuer
B.8 – Starting date of offer to the public or admission to trading
B.9 – Publication date
B.10 – Any other services provided by the issuer
B.11 – Language or 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
B.13 – Functionally fungible group digital Token Identifier, where available
B.14 – Personal data flag
B.15 – LEI eligibility
B.16 – Home member state
B.17 – Host member states
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
C.2 – Number of units
C.3 – Trading platforms
C.4 – Trading platforms Market Identifier Code (MIC)
C.5 – Applicable law
C.6 – Competent court
PART D - INFORMATION ON THE RIGHTS AND OBLIGATIONS ATTACHED TO E-MONEY TOKENS
D.1 – Holder’s rights and obligations
D.2 – Conditions of modifications of rights and obligations
D.3 – Description of the rights of the holders
D.4 – Rights in implementation of recovery plan
D.5 – Rights in implementation of redemption plan
D.6 – Complaint submission contact
D.7 – Complaints handling procedures
D.8 – Dispute resolution mechanism
D.9 – Token value protection schemes
D.10 – Token value protection schemes description
D.11 – Compensation schemes
D.12 – Compensation schemes description
D.13 – Applicable law
D.14 – Competent court
PART E - INFORMATION ON THE UNDERLYING TECHNOLOGY
E.1 – Distributed ledger technology
E.2 – Protocols and technical standards
E.3 – Technology used
E.4 – Purchaser’s technical requirements
E.5 – Consensus mechanism
E.6 – Incentive mechanisms and applicable fees
E.7 – Use of distributed ledger technology
E.8 – DLT functionality description
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 measures
PART G - INFORMATION ON THE SUSTAINABILITY INDICATORS IN RELATION TO ADVERSE IMPACT
ON THE CLIMATE AND OTHER ENVIRONMENT-RELATED ADVERSE IMPACTS
G.1 – Adverse impacts on climate and other environment-related adverse impacts
I.01
Date of notification
I.02
Statement in
accordance with
Article 51(3) of
Regulation (EU)
2023/1114
This crypto asset white paper has not been approved by any competent authority in any Member State of the
European Union. The issuer 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, clear, 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 not covered by the investor compensation schemes under Directive 97/9/EC of the
European Parliament and of the Council or the deposit guarantee schemes under Directive 2014/49/EU of the
European Parliament and of the Council.
SUMMARY
I.05
Warning in
accordance with
Article 51(6),
second
subparagraph of
Regulation (EU)
2023/1114
Warning
This summary should be read as an introduction to the crypto-asset white paper. The prospective holder
should base any decision to purchase this e-money token on the content of the crypto-asset white paper as a
whole and not on this summary alone.
The offer to the public of this crypto asset does not constitute an offer or solicitation to purchase financial
instruments and any such offer or solicitation can be made only by means of a prospectus or other offer
documents pursuant to the applicable national law.
This crypto-asset white paper does not constitute a prospectus as referred to in Regulation (EU) 2017/1129 of
the European Parliament and of the Council or any other offer document pursuant to European Union or
I.06
Characteristics
of the crypto-
USDC is an e-money token ("EMT"), available on public blockchain networks. USDC provides a faster, safer,
asset
For every USDC issued by Circle SAS and remaining in circulation in the European Economic Area ("EEA"),
Circle SAS will hold either one U.S. Dollar ("USD") or an equivalent amount of USD-denominated assets on
behalf of holders, in order to facilitate the frictionless movement of the e-money tokens, utilizing blockchain
technology. As a fully reserved e-money token, USDC is backed by an equivalent amount of U.S. Dollar-
I.07
Right of
redemption
The holders of this e-money token have a right of redemption at any time and at par value. This applies to
holders of USDC resident in the EEA. Conditions and processes for redemption of USDC are detailed in our
Redemption Policy available on Circle’s website (the "Website").
For holders of USDC located outside the EEA, please refer to the specific USDC Terms of Circle Internet
Financial, LLC, organised under the laws of the state of Delaware, USA, with a registered office at 1 Lincoln,
Ste 31-113 Boston, MA, 02111 ("Circle LLC").
I.08
Key information
about the offer
and/ or
admission to
trading
USDC is only available for issuance through the Circle Mint service and it is accessible only to institutions
located in supported jurisdictions. For a complete list of currently supported jurisdictions, please consult our
Website. USDC 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
A.2
Trading name
A.3
Legal form
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
A.7
Legal entity
identifier
A.8
Another
identifier
required
pursuant to
applicable 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
management body
Identity
Business Address
Function
Mrs. Coralie
Billmann
4 RUE DE MARIVAUX, 75002
PARIS – France
4 RUE DE MARIVAUX, 75002
PARIS - FRANCE
Directeur Général
(General Manager)
A.14
Business activity
Circle SAS is a Digital Asset Services Provider registered with the AMF under number E2024-111, authorised
to provide digital assets custody and trading of digital assets against other digital assets since 15 April 2024.
Circle SAS is also an Electronic Money Institution registered with the ACPR under number 17788, and
A.15
Parent company
business activity
Circle Internet Group, Inc. is the holding company for the Circle group. Its shares have been listed on the New
York Stock Exchange since June 5, 2025.
A.16
Conflicts of
interest disclosure
We frequently engage with a wide variety of blockchain and digital asset industry participants, as well as
startups and growth companies, and maintain relationships with a significant number of crypto-asset projects,
developers, and investors. These transactions and relationships could create potential conflicts of interest in
management decisions that we make. For instance, certain of our officers, directors, and employees are 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 projects.
A.17
Issuance
of other
crypto-
assets
A.18
Activities related
to other crypto-
assets
A.19
Connection
between the
issuer and the
entity running the
DLT
A.20
Description of the
connection
between the
issuer and the
entity running the
DLT
USDC is issued on 31 different blockchain networks (see items E.2 and E.3). The list of USDC Supported
Blockchains may be amended from time to time and updated on the following Website
For most of these blockchains, Circle has entered into agreements with the blockchain entity or foundation,
where it exists, responsible for its adoption, by which Circle agrees to design and deploy USDC on blockchain
networks, to make it available on the Circle Mint application, and to offer support to Circle clients accordingly.
Circle, for regulatory reasons (including transaction monitoring), 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 blockchain foundation to support Circle's technical development efforts
through a one-off financial compensatory payment.
A.21
Newly established
A.22
Financial
condition for the
past three years
Not applicable
A.23
Financial condition
since registration
Circle SAS was created on June 30, 2023.
Between June 30, 2023, and July 1, 2024, Circle SAS did not engage in any commercial activities. The
company was formally incorporated on July 10th, 2023, but its operational activities, including the issuance of
EURC and USDC, commenced on July 1, 2024, after the completion of the necessary regulatory approvals.
SAS as of September 30th, 2025 corresponds to €159,000,000.00. In FY2024, Circle SAS reported a turnover
(Net Banking Income) equal to €3,300,119. As of December 31, 2024, Circle SAS reported corporate cash of
A.24
Exemption from
authorisation
A.25
E-money token
authorisation
Circle SAS is a licensed Electronic Money Institution under n°737158 and a registered Digital Assets Services
A.26
Authorisation
authority
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),
second
subparagraph,
of Regulation
(EU) 2023/1114
Not applicable.
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
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
Regulation (EU)
2023/1114
PART B - INFORMATION ABOUT THE E-MONEY TOKEN
B.1
Name
B.2
Abbreviation
B.3
Details of all
natural or legal
persons involved
in design and
development
Identity
Business Address
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-asset
characteristics
USDC is defined as an e-money token pursuant to Article 3.1(7) of MiCA.
As of the date of this White Paper, USDC does not constitute a “significant e-money token” as defined
by Article 56 of MiCA.
USDC is a digital token pegged to the USD and was first issued by Circle LLC in September 2018. From July
1st, 2024, Circle SAS became a second, or "dual”, issuer of USDC.
USDC issued by Circle SAS are fully fungible with those issued by Circle LLC. USDC is fully backed by an
equivalent amount of USD-denominated assets held. There are reserves with Circle SAS for EEA holders and
with Circle LLC for Non-EEA holders. These reserves are held with regulated financial institutions in
segregated accounts separate from Circle SAS’s corporate funds, on behalf of, and for the benefit of, holders
of USDC in the EEA (the "Segregated Accounts"). This means that for every USDC issued by Circle SAS or
by Circle LLC and remaining in circulation, Circle SAS or Circle LLC holds on behalf of holders either one USD
or an equivalent amount of USD-denominated assets in their Segregated Accounts (the "USDC Reserves").
The USDC Reserves are independently reviewed by a leading accounting firm, providing monthly confirmation
that they match or exceed the USDC in circulation. USDC is not designed to create returns for holders,
increase in value, or otherwise accrue financial benefit to the USDC holder.
B.7
Website of the
issuer
B.8
Starting date of
offer to the
public or
admission to
trading
B.9
Publication date
B.10
Any other services
provided by the
issuer
Circle SAS is a registered Digital Assets Services Provider in France under n°E2024-111. It provides Digital
B.11
Language or
languages of the
white paper
B.12
Digital token
identifier code
used to uniquely
identify the
crypto-asset or
each of the
Blockchain
DTI Code
Algorand
several crypto
assets to which
the white paper
relates, where
available
Aptos
Arbitrum
Avalanche
Base
Celo
Codex
Ethereum
Flow (deprecated)
Hedera
HyperEVM (Hyperliquid)
Ink
Linea
Monad
NEAR
Noble
Optimism
Plume
Polkadot Asset Hub
Polygon PoS
Ripple (XRPL)
Solana
Sonic
Stellar
Sei
Sui
Tron (deprecated)
Unichain
World Chain
XDC
ZKsync Era
B.13
Functionally
fungible group
digital token
identifier, where
available
B.14
Personal data flag
B.15
LEI eligibility
B.16
Home Member
State
B.17
Host Member
States
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
C.2
Number of units
C.3
Trading platforms
name
USDC is listed on major global regulated crypto-asset trading platforms operating in the EEA, including for
example Bitstamp, Bitvavo, Kraken, ZBX and OKX. Circle SAS intends to maintain these listings as long as
doing so remains compliant with Applicable Laws.
C.4
Trading
platforms
market identifier
code (MIC)
USDC 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 offer to the public of USDC in the EEA shall be brought exclusively in the Commercial
PART D - INFORMATION ON THE RIGHTS AND OBLIGATIONS ATTACHED TO E-MONEY TOKENS
D.1
Holder’s rights
and
obligations
USDC issued by Circle SAS is an EMT subject to MiCA regulation and Applicable Laws. Under these
regulations, EMT means a type of crypto-asset that purports to maintain a stable value by referencing the value
of one official currency.
Holding USDC tokens does not provide rights to USDC holders other than those rights provided within this
White Paper, as well as under MiCA regulation and Applicable Laws. Persons holding USDC, located outside
the European Economic Area (EEA), shall refer to the Circle Mint User Agreement and/or the applicable USDC
Terms issued by Circle LLC, particularly with respect to the redemption of USDC, and shall not have any right
to seek redemption from Circle SAS. For purposes of this White Paper, the term “USDC Holders” shall refer
exclusively to holders of USDC located within the EEA.
USDC Holders understand that sending USDC to another address automatically transfers and assigns to the
owner of that address, and any subsequent USDC holder, the right to redeem USDC for USD funds so long as
the USDC Holder is eligible to.
USDC transactions are not reversible. Once USDC Holders send USDC to an address, USDC Holders accept
the risk that they may lose access to, and any claim on, that USDC indefinitely or permanently. For example, (i)
an address may have been entered incorrectly and the true owner of the address may never be discovered, (ii)
USDC Holders may not have (or subsequently lose) the private key associated with such address, (iii) an
address may belong to an entity that will not return the USDC, or (iv) an address belongs to an entity that may
return the USDC but first requires action on their part, such as verification of USDC Holders’ identity. For the
avoidance of doubt, Circle SAS does not have to track, verify or determine the provenance of USDC balances
for USDC Holders outside of Circle Mint, including any form of security interests claimed thereon unless
otherwise stated in the Applicable Laws.
USDC Holders have a legal claim against Circle SAS as the EEA issuer of USDC. These holders are entitled to
request redemption of their USDC from Circle SAS. Such redemption will be made at any time and at par
value, subject to complying with AML requirements.
USDC Holders shall have the right to request redemption of their USDC from Circle SAS with respect to any
USDC issued on a blockchain supported by either Circle SAS or Circle LLC.
While Circle SAS may hold the USDC Reserves in interest-bearing accounts or other yield-generating
instruments, USDC Holders acknowledge that they are not entitled to any interest or other returns earned on
such funds. USDC does not itself generate any interest or return for USDC Holders and only represents your
right to redeem USDC for an equivalent amount of USD as provided in the present White Paper.
As required by its license, Circle SAS will validate and process redemptions for USDC Holders that
successfully pass prior Anti-Money Laundering ("AML") checks, which include:
● Collection of relevant Know Your Customer documents;
● Verification of identity and screening versus international sanctions lists;
● Verification of bank details; and
● Circle’s Compliance department validation.
More information on the redemption of USDC within the EEA is provided in the Circle SAS Redemption Policy
available on Circle’s Website.
The holding of USDC will not result in: (i) the creation or imposition of any lien upon any property, asset, or
revenue of Circle SAS or (ii) the creation of any shareholding or ownership interest in Circle SAS, Circle LLC,
or any of their respective affiliates.
By holding, using, or accessing USDC, USDC Holders further represent and warrant that:
● they are holding and using USDC in compliance with this White Paper and Applicable Laws;
● they are at least 18 years old, are not a Restricted Person (as defined in the Redemption Policy), are
not owned or controlled by a Restricted Person. and are not holding USDC on behalf of a Restricted
Person; and
● they will not be using USDC for any illegal activity including, but not limited to, illegal gambling, money
laundering, fraud, blackmail, extortion, ransoming data, terrorism financing, other violent activities, or
any prohibited market practices. For more details, please consult Circle’s Acceptable Use Policy.
USDC Holders accept that Circle SAS reserves the right to block certain USDC addresses that it determines, in
its sole discretion, may be associated with illegal activity or activity that otherwise violates Circle SAS’s Terms
of Use and/or this White Paper ("Blocked Address(es)"). In certain circumstances, Circle SAS may deem it
necessary to report such suspected illegal activity to relevant law enforcement agencies and USDC Holders
may forfeit any rights associated with their USDC, including the ability to redeem USDC for USD. Circle SAS
may also be required to freeze USDC and/or surrender associated USD held in segregated accounts in the
event it receives a legal order from a valid government authority requiring it to do so.
USDC is also issued and redeemed in accordance with Circle's Stablecoin Access Denial Policy. Circle SAS
reserves the right to block the transfer of USDC to and from an address on chain as permitted under such
policy.
USDC Holders shall hold and use USDC exclusively for their own account and shall in no case be considered
as nominees or agents of Circle SAS, unless otherwise expressly agreed in writing by Circle SAS.
USDC Holders are duly informed that Circle SAS’s liability (and its affiliates, its respective officers, directors,
agents, joint venturers, employees, and suppliers) is limited to what is expressly provided in the Applicable
Laws and the present White Paper. In particular (but without limitation), USDC Holders are duly informed and
acknowledge that Circle SAS shall bear no liability with regard to i) their use of USDC; (ii) claims or issue
concerning the cost of procurement of substitute goods and services resulting from any goods, data,
information, or services purchased or obtained or messages received or transactions entered into involving
USDC; or (iii) unauthorised access to or alteration of USDC Holders transmissions or data incurred by the use
of USDC.
In this respect, to the full extent permissible by Applicable Laws, Circle SAS disclaims all warranties, express or
implied, including, but not limited to, implied warranties of merchantability and fitness for a particular purpose.
To the full extent permissible by Applicable Laws, Circle SAS shall not be liable for any damages of any kind
arising from the use of USDC, including, but not limited to direct, indirect, incidental, punitive and consequential
D.2
Conditions of
modifications of
rights and
obligations
The rights and obligations associated with USDC and applicable to EEA holders are available in the
Redemption Policy and Terms of Use available on Circle’s Website.
Circle SAS reserves the right to amend these rights and obligations from time to time, and will 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 valid, including on Circle’s Website.
As provided by Article 51 of MiCA regulation, any significant new factor, any material mistake or any material
inaccuracy that would be capable of affecting the assessment of USDC will be described in a modified 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 implementation by Circle SAS of its Recovery Plan or Redemption Plan
(please refer to Sections D.4 and D.5 below).
D.3
Description of
the rights of the
holders
Should it become insolvent, Circle SAS has implemented high standards for safe and sound financial
management of its business. In a situation of financial duress or in periods of economic uncertainty, Circle SAS
has established contingency plans to prevent any impact on its activities, including the issuance of USDC, or
the rights of USDC Holders.
Where Circle SAS is not able to fulfill its obligations or in the event of insolvency, the USDC Reserves are duly
protected in compliance with the Applicable Laws. In particular, the funds received in exchange for issuance of
USDC 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/or
Redemption Plan to allow USDC Holders to exercise their redemption rights on USDC as further specified in
D.4
Rights in
implementation of
recovery plan
Depending on the specific circumstance(s) under which the Recovery Plan implemented by Circle 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 USDC.
USDC Holders will be duly informed about any such restrictions on Circle’s Website. Customers will also be
informed via their Circle Mint Account or another valid means of communication between Circle SAS and the
Customer. For instance, Circle SAS may temporarily impose:
● liquidity fees on redemptions;
● limits on the amount of USDC that can be redeemed 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;
● suspension of redemptions, as a last resort.
Example actions listed above don’t constitute an exhaustive list; other actions may be taken by Circle SAS in
accordance with its Recovery Plan
These restrictions will be implemented during periods of market stress and Circle SAS will work to restore
D.5
Rights in
implementation of
redemption plan
The Redemption Plan implemented by Circle SAS in compliance with Article 55 of MiCA is an operational plan
to support the orderly redemption of USDC in circulation.
The Redemption Plan will be triggered upon a decision by the ACPR if Circle SAS is unable or likely to be
unable to fulfill its obligations, including in the case of insolvency, resolution, or the withdrawal of authorisation
of Circle SAS as an E-Money Institution. The processes set forth in the Redemption Plan will be established
with a view to ensuring the equitable treatment of all USDC holders and the protection of the right of
redemption attached to USDC as described above.
If the ACPR triggers the implementation of the Redemption Plan, any individual claim under Section D.1 above
will be suspended. Circle SAS will commence the orderly redemption for all USDC Holders in an equitable
manner.
As part of this process, a notice will be published informing all USDC 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 time when the redemption plan has been activated, the minimum
information necessary to file a redemption claim, where the claim should be filed, and the time frame within
which USDC Holders are required to file their claim. The notice will also contain important information
regarding redemption conditions and technical support.
Redemption requests submitted via a redemption claim form will be subject to certain eligibility criteria
described in the Redemption Policy, and as further specified in the Redemption Plan notice information,
including their identity, their token holdings, AML/CFT compliance, their bank account details, and other
D.6
Complaint
submission
contact
If you have a complaint, please first contact Circle SAS at EEA-Customer-Support@circle.com, or visit the
Circle Support Portal.
D.7
Complaints
handling
procedures
USDC Holders 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. Upon receiving a complaint, 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 details of the complaint.
Circle SAS handles complaints submitted by its direct Customers or by USDC Holders experiencing issues with
the USDC redemption process for their USDC. However, complaints relating to the purchase of USDC from third
parties or to the loss of tokens held in self-custody or custodied with third parties fall outside the scope of Circle
SAS's Customer Care support.
If appropriate, all details and data will be compiled and escalated to the Legal Department. When such an
escalation occurs, the Legal Department is responsible 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 Customer Care Department will remain actively involved in any customer complaint or service requirement
and serves as a first line of support and an advocate for 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 their complaint is not satisfactory, USDC Holders and customers can
refer their claim to the ACPR:
● By mail sent to the following address:
Banque de France - ACPR
TSA 50120
75035 PARIS CEDEX 01
● By electronic means, by creating an account on the online application portal of the Banque de France
D.9
Token value
protection
schemes
D.10
Token value
protection
schemes
As a MiCA compliant regulated e-money token, USDC will be fully backed by an equivalent amount of USD-
denominated assets held by Circle SAS with regulated financial institutions in segregated accounts apart from
description
D.11
Compensation
schemes
D.12
Compensation
schemes
description
D.13
Applicable law
D.14
Competent court
Any dispute concerning the rights and obligations of EEA residents arising out of the use or ownership of
USDC shall be brought exclusively to the Commercial courts of Paris, France, except where provided
PART E - INFORMATION ON THE UNDERLYING TECHNOLOGY
E.1
Distributed ledger
technology
E.2
Protocols and
technical
standards
Circle has developed its technical e-money token specification for deploying USDC 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 USDC.
For not natively EVM compatible networks (Algorand, Aptos, Hedera, NEAR, Noble, Polkadot, Solana, Sui,
Stellar, XRPL, Flow, Tron), Circle SAS has assessed the existing available Token Standards for each base
layer and deployed USDC on the Token Standard that is best suited for Circle SAS’s specifications and
required functionality.
Blockchain
Token Standard
Algorand
ASA (Algorand Standard Assets)
Aptos
Dispatchable Fungible Asset
Arbitrum One
ERC-20
Avalanche
ERC-20
Base
ERC-20
Celo
ERC-20
Codex
ERC-20
Ethereum
ERC-20
Flow (deprecated)
FungibleToken (Cadence). USDC on Flow was originally
implemented using the Cadence FungibleToken
standard, with Circle’s FiatToken contract including
extensions (pausable, blocklisting). Following Flow’s
“Crescendo” upgrade (September 2024), the chain
transitioned toward ERC-20 compatibility, but Circle has
discontinued issuance; only redemptions remain
supported.
Hedera
Hedera Token
HyperEVM (Hyperliquid)
ERC-20
Ink
ERC-20
Linea
ERC-20
Monad
ERC-20
NEAR
NEP-141
Noble
FiatTokenFactory (Circle module)
Optimism
ERC-20
Plume
ERC-20
Polkadot Asset Hub
Polkadot Assets
Polygon PoS
ERC-20
Ripple (XRPL)
XRPL Fungible Token Standard
Solana
SPL Token
Sonic
ERC-20
Stellar
Stellar Assets
Sui
RegulatedCoin
Sei
ERC-20
Tron (deprecated)
TRC-20
Unichain
ERC-20
World Chain
ERC-20
XDC
XRC-20
ZKsync Era
ERC-20
USDC is deployed using upgradeable smart contract architectures via the proxy patterns of the Universal
Upgradeable Proxy Standard (UUPS) – introduced via ERC-1822 – on Arbitrum, Avalanche, Base, Celo,
Ethereum, HyperEVM, Ink, Optimism, Plume, Polygon, Sei, Sonic, XDC and zkSync, and more generally, on all
EVM chains. These implementations allow the contract logic to be modified without changing the token
address. Aptos, Algorand, Hedera, NEAR, Noble, Polkadot, Sui, and Stellar’s native token standards follow
their own upgradeable proxy model. The upgradeable smart contract architectures include the UUPS proxy
pattern, allowing contract logic to be updated without changing the token address. Despite these additions, the
contracts preserve the expected ERC-20 behaviour, such as transfer, approve, and balance.
While USDC is available on 31 blockchain networks ("USDC Supported Blockchains") to date, Circle will
likely add additional blockchain support in the future and will update the list of USDC Supported Blockchains on
its Website.
Circle may, based on factors such as transaction volumes or compliance considerations, decide to discontinue
support for certain USDC Supported Blockchains. In such cases, the process for exchange or redemption by
USDC Holders on the affected blockchains will be published on Circle’s Website. As of the date of this White
Paper, the following blockchains have already been deprecated:
● Tron: Circle announced on February 21, 2024, that it would immediately cease minting USDC on the
Tron blockchain. Transfers to supported blockchains and redemptions continue to be operated for
USDC Holders.
● Flow: Circle announced in August 2024 that it would discontinue support for USDC on Flow due to the
chain’s “Crescendo” network upgrade (Circle blog). Minting stopped on August 27, 2024, and all
support ceased on September 3, 2024, when Circle froze remaining balances and began a manual
redemption process on September 4, 2024. Circle supports manual redemptions for Flow USDC
holders who meet the eligibility criteria as outlined in this Help Center article.
E.3
Technology used
USDC integrates with a range of supporting technologies beyond its smart-contract implementations. Circle
provides fiat on- and off-ramp functionality, transaction monitoring, and identity-verification workflows,
facilitating compliance-aligned integrations for exchanges, custodians, and fintech platforms.
On EVM-compatible networks, USDC is fully interoperable with the standard JSON-RPC interface and
commonly used libraries such as Web3.js and Ethers.js, ensuring compatibility with Ethereum tooling. On non-
EVM blockchains, USDC interacts through each chain’s native communication and SDK interfaces.
USDC metadata handling—relevant to contract interfaces, block explorers, token lists, and wallet
integrations—is implemented through established conventions. On EVM blockchains, USDC contracts expose
the standard ERC-20 metadata functions. On non-EVM blockchains, basic metadata is also stored on-chain in
the smart-contract state (except as noted below):
● Algorand – on-chain via ASA parameters
● Hedera – on-chain in the native token object
● Noble – on-chain in the fiattokenfactory module
● Solana – USDC (legacy mint) keeps its metadata off-chain in the public Solana Token List JSON file¹,
while the newer EURC mint stores metadata on-chain through the Metaplex Metadata Program
● Stellar – off-chain through a stellar.toml file hosted by Circle
● XRPL – off-chain through an xrp-ledger.toml file hosted by Circle
Because wallet integration is broadly supported—with USDC recognised and rendered by all major Web3
wallets—these conventions ensure consistent user display and interaction across networks.
E.4
Purchaser’s
technical
requirements
Circle Mint, Circle SAS’s service that allows its customers to access USDC 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 USDC on the secondary market, for example, 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 USDC Holders must use wallets compatible with the blockchains on which USDC is natively
issued.
Usage of USDC requires the USDC Holders to cover network fees, which may be gas fees on Ethereum, Layer
2s (Arbitrum One, Base, Ink, Linea, Polygon PoS, Optimism, Unichain, World Chain, zKSync Era) and other
EVM-compatible blockchains (Avalanche, Celo, Codex, HyperEVM, Monad, Plume, Sonic, Sei, XDC), and
E.5
Consensus
mechanism
Not applicable as USDC is a token and therefore does not have a consensus mechanism. USDC runs on base
layers, which may be blockchains 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
E.6
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.
E.7
Use of
distributed
ledger
technology
E.8
DLT functionality
description
E.9
Audit
E.10
Audit outcome
Circle LLC, as a co-issuer of USDC and as technical provider to Circle SAS, is responsible for ensuring that its
smart contracts are developed in a safe and secure manner. As such, Circle works with industry leading
security auditing firms such as Chain Security, OtterSec, and others, to audit every USDC smart contract prior
to launch or upgrade.
Any identified issues during these audits are reviewed, validated, assessed and remediated according to their
severity prior to launch or upgrade.
As a matter of best practice and policy, Circle SAS always open-sources every USDC 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 public vulnerability disclosure program and a private bug
bounty program via HackerOne that enables vulnerabilities to be disclosed to Circle.
As part of Circle SAS’s blockchain due diligence process when it evaluates deploying USDC on new
blockchains, Circle SAS requires independent security audits to be performed on the blockchains themselves.
As a matter of policy, all audit results are internally reviewed, validated, assessed, and remediated according to
PART F - INFORMATION ON RISKS
F.1
Issuer-related
risks
As part of the USDC issuance process, Circle SAS is exposed to several risks:
1. Bankruptcy Risks. This is the risk of Circle SAS going bankrupt, which could result from the insolvency
of Circle SAS as part of its activities, the failure of a bank holding Circle SAS own funds or USDC
reserves, or other systemic financial risks that could impact the operations and financial solvency of
Circle SAS.
2. Third-Party Risks. This is the risk Circle SAS faces in its business relationships with one or more 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 safeguarding 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 USDC. Third parties can elect to support USDC on their
platforms without any authorisation or approval by Circle SAS or anyone else. As a result, USDC
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. Circle SAS is not responsible for any losses or
other issues encountered using USDC on third-party platforms.
3. Market Risks. This is the risk that USDC Reserves may include assets that are 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 USDC, Circle SAS may not be able to fulfill all the redemption requests
within the timeframe provided for in the Redemption Policy.
4. Risk of Loss. This is the risk of loss caused by fraud, theft, misuse, negligence, or improper
administration of USDC or the USDC Reserves.
5. Dual-issuer Risk. This is the risk that Circle LLC may not be able, temporarily or permanently, to
rebalance all or part of the USDC Reserves to Circle SAS, in the event that holdings and redemptions
of USDC shift significantly towards the EEA, impacting Circle SAS’s ability to cover redemption
requests.
6. Anti-Money Laundering/Counter-Terrorism Financing Risks ("AML/CTF"). This is the risk that
crypto-asset wallets holding USDC or transactions in USDC may be used for money laundering or
terrorist financing purposes, or identified to a person known to have committed such offenses.
7. Personal Data Risks. This is the risk that the personal data of Circle SAS customers may be leaked or
stolen due to a security breach.
8. Risks Related to Circle SAS’s Business Activities and Industry. This is the risk that results from
Circle SAS operating in a rapidly changing, regulatorily fragmented, and highly competitive industry.
9. 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 jurisdictions that Circle SAS operates in.
Further, Circle SAS could be subjected to investigations, enforcement actions, and penalties. Circle
SAS could also be subject to private litigation.
10. Internal Control Risk. Any failure to develop or maintain effective internal controls, or any difficulties
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 lead to a loss of trust in the business.
11. Environmental, Social, and Governance Risks. Circle SAS issues USDC on various public
blockchains which use different consensus algorithms. Each public blockchain, depending notably on its
consensus algorithm, has certain environmental impacts. Please see Section G below for sustainability
disclosures for USDC on each individual blockchain. USDC is not issued on blockchains using the most
energy-intensive proof-of-work consensus mechanism, and the blockchains currently supported by
Circle SAS generally use Proof-of-Stake (or a modified version of that mechanism), the environmental
impacts of which are very limited compared to Proof-of-Work. In the future, environmental regulations
affecting consensus mechanisms may restrict Circle SAS’s ability to issue USDC on individual public
blockchains if their sustainability impact is considered too negative.
12. Outsourcing Risk. This is the risk that Circle SAS becomes structurally dependent on Circle LLC for
critical services.
F.2
Token-related
risks
1. Financial Stability Risks. Since USDC is a major stablecoin that is used by and integrated in many
significant market infrastructures (e.g. crypto-asset trading platforms), a problem affecting USDC could
indirectly impact these infrastructures and cause temporary instability.
2. Secondary Market Price Dislocation Risk. This is the risk that the market value of USDC on the
secondary market is not stable compared to the USD. This price dislocation 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, due to fraud or mismanagement (by either Circle
SAS, Circle LLC, or a third-party provider), the value of the reserve of assets backing the redeemability
of USDC becomes lower than the outstanding quantity of USDC. That risk would likely cause a price
dislocation of the market value of USDC (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 risk that the USDC Reserves may include assets that are not readily
liquidated (such as certain short-term financial securities) or any technical and operational issues causing
delays and liquidity risk (e.g. loss of APIs or correspondent issues). In that case, if there is an exceptionally
high demand for redemption of USDC, Circle SAS may not be able to fulfill all the redemption requests
within the timeframe provided 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 from a scam or fraud suffered by USDC 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 its executive members, creation of fake USDC
tokens, offering fake USDC airdrops, among others.
6. Taxation Risks. The taxation regime that applies to USDC 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 USDC, or conversions of other crypto-assets against USDC, will
not incur tax consequences. In addition, USDC Holders should be warned that, based on the current
provisions of MiCA, USDC could qualify both as a crypto-asset and as electronic money. Which legal
classification prevails might vary amongst national competent authorities and will likely impact the tax
treatment of USDC transactions within the EEA.
7. Legal and Regulatory Risk. This risk stems from the fact that e-money tokens and crypto-asset
services are unregulated in certain jurisdictions outside of the EEA. There is also a lack of regulatory
harmonisation and cohesion globally which could lead to diverging regulatory frameworks globally
F.3
Technology-
related risks
Purchasing and using USDC may also expose the holder to technological risks.
1. Blockchain Risks. One or several of the blockchain network(s) on which USDC is issued may be
subject to technical vulnerabilities and be exposed to attacks that could lead to a general network
disruption, such as unexpected pauses in transactions, inability to proceed with transfers of USDC,
major losses for network participants, or unexpected liquidity movements.
2. Smart Contract Risks. The smart contracts deployed by Circle SAS to mint or burn USDC on the
various blockchains or to ensure the transfer of USDC (notably to other blockchains) may be exposed
to technical vulnerabilities that could lead to losses for USDC Holders.
3. Settlement Finality or Irrevocability of Blockchain Transactions. Depending on the tools and
services providers used to initiate USDC transactions, these transactions may be irreversible. Once you
send USDC to a blockchain address, you accept the risk that you may lose access to, and any claim
on, that USDC indefinitely or permanently. For example: (i) a blockchain 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 private key associated with such address, (iii) a blockchain address may
belong to an entity that will not return the USDC, or (iv) a blockchain address may belong to an entity
that may return the USDC, but first requires action on your part, such as verification of your identity.
4. Personal Data Risks. Pursuant to the General Data Protection Regulation ("GDPR"), Circle SAS is
required to take all necessary precautions: (i) with regard to the nature of the data collected and the
risks presented by the processing of such data, (ii) to preserve the security of USDC Holders' personal
data and, (iii) in particular, to prevent such data from being distorted, damaged, or accessed by
unauthorised third parties.
5. Unanticipated Risks. E-money tokens such as USDC are a relatively new and untested technology. In
addition to the risks included in this section, there might be other risks that cannot be foreseen.
Additional risks may also materialize as unanticipated variations or combinations of the risks discussed
F.4
Mitigation
measures
Regarding the different risks identified in Sections F1, F2 and F3, Circle SAS implements appropriate
measures to mitigate these risks and protect its customers, as follows:
1. Mitigation measures concerning issuer-related risks
Circle SAS has implemented a comprehensive Risk Management and Internal Control Framework grounded in
the Three Lines of Defense model. The first line, comprising business and operational teams, owns and
manages risks in day-to-day activities. The second line, composed of compliance, security and risk
management functions, provides independent oversight and ensures policies, controls, and processes are
robust and effective. The third line, internal audit, conducts independent assessments of the control
environment. Circle SAS performs regular and proactive risk assessments to identify, evaluate, and 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, ensuring 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 precedent, Circle SAS's bankruptcy should have no impact on
the rights of USDC Holders. If Circle SAS goes bankrupt, the USDC Reserves are protected by Applicable Law
and cannot be used to compensate Circle SAS’s other creditors. Bank accounts used by Circle SAS for the
USDC Reserves are safeguarded from Circle SAS creditors as provided by Applicable Law. Any USDC will be
refunded to its holders as part of Circle SAS's bankruptcy proceedings, without the holder necessarily having to
file a claim for compensation.
1.2. Third-party Risks. When Circle SAS relies on a third party to provide services that are important to
USDC, Circle SAS generally enters into an agreement containing specific clauses ensuring that 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 the USDC Reserves) are also subject
to regulatory obligations. In addition, Circle SAS implements internal procedures whose purpose is to limit
disruption in the event that an important service provider terminates an agreement or becomes unable to
provide its services to Circle SAS. Finally, third parties 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 diversification strategy, aiming to avoid excessive concentration
with any single banking, custody, or operational partner. This includes maintaining relationships with multiple
safeguarding institutions and service providers where feasible, regularly assessing diversification metrics, and
establishing contingency options to ensure operational continuity in the event of a third-party failure or service
interruption.
1.3. Market Risks. Circle SAS’s systems and procedures are set up in a way that ensures that USDC
redemptions will occur in the timeframe set out in the Redemption Policy, even if volatility in crypto-asset
markets causes a significant increase in redemption requests.
1.4. Dual Issuer Risk. USDC is fully fungible globally and Circle France’s Minimum Reserve Requirement is
equal to EEA holdings of USDC at all times. The USDC Reserves Rebalancing Procedure and related
contractual agreement ensures that both entities will rebalance their respective reserves in the event that such
requirement is not met. The Circle SAS Recovery Plan and Redemption Plan will take into account these intra-
group considerations and outline a uniform and coordinated approach by both issuers in order to be able to
cover any outstanding liabilities and satisfy redemptions in a prompt and equitable way.
1.5. Risks of Loss. The redemption right of eligible USDC Holders remains exercisable even if Circle 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 institution, Circle SAS is subject to regulatory capital and
own-funds requirements. In the event that the loss should exceed Circle SAS’s ability to redeem the USDC
Holders, the Redemption Plan may be triggered to ensure equitable treatment of all USDC Holders.
1.6. AML/CFT Risks. Each USDC redemption request to Circle SAS requires the holder to comply with the
laws and regulations applicable to anti-money laundering and counter-terrorist financing in the EU. Moreover, if
Circle SAS determines that USDC transactions linked to public addresses are likely to be associated with
Circle SAS receives an injunction from a competent authority to freeze USDC, Circle SAS will comply with such
a request.
1.7. Personal Data Risks. Pursuant to the GDPR, Circle SAS is required to take all necessary precautions
with regard to the nature of the data and the risks presented by the processing of such data, to preserve the
security of USDC Holders' personal data and, in particular, to prevent it from being distorted, damaged, or
accessed by unauthorised third parties.
2. Mitigation measures concerning the token-related risks
2.1. Financial Stability Risks. USDC has been issued since 2018 and has withstood several major volatility
events and liquidity crises. Circle SAS’s internal procedures such as robust Reserve Management policies,
diversification of banking partners, periodic reconciliation, business continuity and risk management framework
ensure that USDC can reliably be used by market participants and market infrastructures under all market
conditions.
2.2. Secondary Market Price Dislocation Risk. Circle SAS expects that any disparity between the USDC
price and USD on secondary markets would be promptly resolved by market participants (i.e. buying USDC for
less than 1 USD on the secondary market and redeeming it at par value with Circle SAS), as any participant
will be entitled to redeem at par with Circle SAS. Otherwise, if the price dislocation is caused by an inadequacy
of the USDC Reserves or other liquidity issues, Circle SAS will apply the measures set out in its Recovery Plan
or Redemption Plan.
2.3. Risks of Under-Collateralisation. If the USDC Reserves become lower than the outstanding quantity of
USDC in circulation, Circle SAS may apply measures set out in its Contingency Funding Plan, Recovery Plan
or Redemption Plan. These plans include measures that could resolve the under-collateralisation through for
example backstoping any loss incurred within the USDC reserve with Circle’s own corporate assets.
2.4. Liquidity Risk. Circle SAS has implemented a Redemption Policy designed to ensure the prompt
redemption of USDC and to respond to scenarios of extreme demand for redemption in unfavorable market
conditions. Circle also looks to expand its settlement banking footprint with major banking partners to limit
Liquidity Risk.
2.5. Scam Risks. Circle SAS cannot prevent all attempts to defraud or scams in connection with USDC. The
general terms and conditions relating to USDC issuance specify that Circle SAS is not liable for this type of
loss. From time to time, Circle SAS will inform its clients of such risks through various channels.
2.6. Taxation Risks. The tax consequences of USDC transactions should be assessed at the level of each
USDC holder. It is the sole responsibility of USDC Holders to address taxation risks in consideration of their
personal situation. Circle SAS and its affiliates does not provide, nor accept responsibility for, any legal, tax or
accounting advice. If USDC Holders are unsure regarding any of the legal, tax or accounting aspects of their
situation regarding USDC, they should seek independent professional advice.
3. Mitigation measures concerning technology-related risks
3.1. Blockchain related Risks. While risks exist for all blockchain networks, blockchain networks used by
Circle SAS to issue USDC are recognised for their high level of security and have generally withstood several
major events without any interruption to their normal functioning. Before launching USDC on any new
blockchain, Circle SAS conducts thorough due diligence, including blockchain-level security audits, as well as
the review of the history of the blockchain, the level of decentralisation, and the degree of resilience or activity
on the network.
3.2. Smart Contract Risks. To reinforce the resilience of the smart contracts for USDC issuance, Circle SAS
is making the contract addresses linked to USDC 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 USDC issuance has been audited. In the event of a
modification to the source code, the smart contract is audited again to ensure that no potential security exploit
can be used to fraudulently use the USDC mint or burn system or to circumvent its initial use by other means.
More specific information on the audits carried out on the USDC is detailed in Section E.3.
3.3. Settlement Finality or Irrevocability of Blockchain Transactions. Circle SAS cannot prevent
blockchain transactions from being irreversible and in many cases, will not be able to mitigate this risk, noting
that irrevocability is also a major security element of blockchain 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 of
communication.
3.4. Security Program. Circle SAS is supported by a dedicated cybersecurity team that monitors the
technology environment 24/7, implements multiple layers of security defenses, and performs ongoing security
G – Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts
Mandatory Information on principal adverse impacts on the climate
N
Field
Content
General Information
S.1
Name
S.2
Relevant legal
entity identifier
S.3
Name of the
crypto-asset
S.4
Consensus
Mechanism
Not applicable as USDC is a token and therefore does not have a consensus mechanism. USDC runs on base layers,
which may be blockchains 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
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
N
Field
Content
General Information
S.7
End of the
period to which
the disclosure
relates
Mandatory key indicator on energy consumption
S.8
Energy
consumption
Base layer
kWh per calendar year
Algorand
1,038.31438
Aptos
0.96536
Arbitrum One
6,753.52664
Avalanche
2,606.71910
Base
56.74208
Celo
223.12948
Codex
0.00000
Ethereum
5,824.09616
Flow
18.59182
Hedera
0.00002
HyperEVM
0.50121
N
Field
Content
General Information
Ink
4.02577
Linea
0.78373
Monad
8.17312
NEAR
0.06994
Noble
2.38256
Optimism
8.92221
Plume
0.00051
Polkadot Asset Hub
6.70291
Polygon
6.55124
Sei
1.00375
Solana
72,811.73205
Sonic
868.67386
Stellar
617.64351
Sui
82.89684
Tron
5.46807
Unichain
1.72695
World Chain
0.01728
XDC
132.19690
N
Field
Content
General Information
XRPL
16.11411
ZKSync
0.00139
Total
Sources and methodologies
S.9
Energy
consumption
sources and
methodologies
Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of
Commission Delegated Regulation (EU) 2025/422, Article 6(5). As the base layers are decentralised networks,
estimates on individual node power draw are used. Values for HyperEVM, Ink, Sei and XDC correspond to October
2025. Since the Monad blockchain is in the testnet and has not been launched, assumptions on future throughput of
USDC on Monad are made and their values are thus not included in the total field for S.8, S.10, S.11, S.12, S.13 and
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)
Algorand
39.3002877244%
Aptos
36.7943144021%
Arbitrum One
44.0006804884%
Avalanche
35.3318926442%
Base
39.0326707634%
Celo
39.6545985875%
Codex
39.9412986134%
Ethereum
35.4272282688%
Flow
31.6736704539%
Hedera
38.7353382169%
HyperEVM
39.7914565339%
Ink
39.8716067977%
Linea
38.8770215445%
Monad
35.6673557073%
NEAR
39.0196302710%
Noble
39.8471533795%
Optimism
38.8349396075%
Plume
39.5299063929%
Polkadot Asset Hub
38.4185375915%
Polygon PoS
39.0139873629%
Sei
38.8269469969%
Solana
40.5646569227%
Sonic
39.8537573663%
Stellar
38.8450452475%
Sui
38.9885598088%
Tron
32.0154425345%
Unichain
39.8499456046%
World Chain
39.9321338066%
XDC
38.9145620574%
XRPL
36.4496554839%
ZKSync Era
38.8652936510%
Total
S.11
Energy intensity
Base layer
kWh per transaction
Algorand
0.0000762554
Aptos
0.0000007137
Arbitrum One
0.0000275328
Avalanche
0.0000283013
Base
0.0000001049
Celo
0.0000211845
Codex
0.0000000009
Ethereum
0.0000752403
Flow
0.0002029342
Hedera
0.0000000002
HyperEVM
0.0000000407
Ink
0.0000000538
Linea
0.0000000354
Monad
0.0000000395
NEAR
0.0000108718
Noble
0.0000003880
Optimism
0.0000000782
Plume
0.0000000237
Polkadot Asset Hub
0.0001754690
Polygon PoS
0.0000000388
Sei
0.0000000177
Solana
0.0000358439
Sonic
0.0000088492
Stellar
0.0000036917
Sui
0.0000011707
Tron
0.0000411904
Unichain
0.0000000279
World Chain
0.0000000266
XDC
0.0195422634
XRPL
0.0000010972
ZKSync Era
0.0000000187
Total
S.12
Scope 1 DLT
GHG emissions
– controlled
Base layer
t CO2eq per calendar year
Algorand
0
Aptos
0
Arbitrum One
0
Avalanche
0
Base
0
Celo
0
Codex
0
Ethereum
0
Hedera
0
Linea
0
NEAR
0
Noble
0
Optimism
0
Polkadot Asset Hub
0
Polygon PoS
0
Solana
0
Sonic
0
Stellar
0
Sui
0
Unichain
0
World Chain
0
XRPL
0
ZKSync Era
0
Total
S.13
Scope 2 DLT
GHG emissions
– purchased
Base layer
t CO2eq per calendar year
Algorand
0.30636
Aptos
0.00029
Arbitrum One
2.06177
Avalanche
0.81646
Base
0.01682
Celo
0.06548
Codex
0.00000
Ethereum
1.85407
Flow
0.00574
Hedera
0.00000
HyperEVM
0.00015
Ink
0.00118
Linea
0.00023
Monad
0.83413
NEAR
0.00002
Noble
0.00007
Optimism
0.00265
Plume
0.00000
Polkadot Asset Hub
0.00199
Polygon PoS
0.00194
Sei
0.00030
Solana
20.39564
Sonic
0.25467
Stellar
0.18357
Sui
0.02461
Tron
0.00199
Unichain
0.00051
World Chain
0.00001
XDC
0.03930
XRPL
0.00480
ZKSync Era
0.00000
Total
S.14
GHG intensity
Base layer
kg CO2eq per transaction
Algorand
0.0001257102
Aptos
0.0000002697
Arbitrum One
0.0000426190
Avalanche
0.0000495275
Base
0.0000001576
Celo
0.0000062165
Codex
0.0000000003
Ethereum
0.0001150340
Flow
0.0003500503
Hedera
0.0000000003
HyperEVM
0.0000000119
Ink
0.0000000157
Linea
0.0000000534
Monad
0.0000040289
NEAR
0.0000180257
Noble
0.0000001137
Optimism
0.0000001180
Plume
0.0000000070
Polkadot Asset Hub
0.0002906460
Polygon PoS
0.0000000584
Sei
0.0000000253
Solana
0.0000122291
Sonic
0.0000025943
Stellar
0.0000013858
Sui
0.0000004234
Tron
0.0000837295
Unichain
0.0000000082
World Chain
0.0000000078
XDC
0.0070764066
XRPL
0.0000018275
ZKSync Era
0.0000000282
Total
Sources and methodologies
S.15
Key energy
sources and
methodologies
Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of
Commission Delegated Regulation (EU) 2025/422, Article 6(5). Since the Monad blockchain is in the testnet and has
not been launched, assumptions on future throughput of USDC on Monad are made and their values are thus not
included in the total field for S.8, S.10, S.11, S.12, S.13 and S.14. Values for HyperEVM, Ink, Sei and XDC correspond
to October 2025.
S.16
Key GHG
sources and
methodologies
Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of
Commission Delegated Regulation (EU) 2025/422, Article 6(5). Since the Monad blockchain is in the testnet and has
not been launched, assumptions on future throughput of USDC on Monad are made and their values are thus not
included in the total field for S.8, S.10, S.11, S.12, S.13 and S.14. Values for HyperEVM, Ink, Sei and XDC correspond
to October 2025.
