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ECB paper says DeFi DAOs may be too centralized for MiCA loophole

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ECB paper says DeFi DAOs may be too centralized for MiCA loophole

Summary

  • ECB staff paper finds top 100 holders in Aave, MakerDAO, Ampleforth and Uniswap control over 80% of governance tokens.
  • Concentrated voting blocs threaten DeFi protocols’ claims to “fully decentralized” status under MiCA.
  • Findings raise risk that leading DeFi DAOs could be pulled inside the EU’s licensing and compliance regime.

The European Central Bank (ECB) has published a working paper arguing that governance in flagship DeFi protocols like Aave, MakerDAO, Ampleforth and Uniswap is far more centralized than their “decentralized autonomous organization” branding suggests, a conclusion that could strip them of regulatory safe harbor under the EU’s MiCA regime. The staff study, titled “Who to regulate? Identifying actors within DeFi’s governance,” finds that the top 100 holders in each of the four protocols collectively control more than 80% of governance token supply, with “around half or more holdings linked” to the protocols themselves or exchanges.

According to the ECB researchers, voting power is even more concentrated than token ownership, with top voters “mostly delegates, who, in many cases, could not be identified nor linked to token holders.” In Ampleforth, the paper highlights that the top 20 voters account for roughly 96% of proxy voting rights, a structure that leaves real control in the hands of a small, opaque elite. That concentration, the authors warn, turns many DAOs into what prior academic work has called “minority rule,” where a few large token holders or delegates can effectively dictate protocol outcomes.

Under the EU’s Markets in Crypto-Assets regulation, crypto-asset services that are “provided in a fully decentralised manner without any intermediary” can fall outside the core licensing perimeter. The ECB paper directly questions whether Aave, MakerDAO’s Sky ecosystem, Uniswap and Ampleforth can plausibly claim that status when more than half of governance tokens in some cases are linked to founding teams or centralized exchanges such as Binance. “The concentration of governance power remains stable over time,” the authors write, arguing that decentralization here is “form over substance.”

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For policymakers, the study’s aim is explicit: identify “regulatory anchor points” in systems that were designed to avoid having a traditional issuer, board or CEO. The authors stress that limited on-chain transparency about the real-world identities behind key delegates “complicates efforts to assess accountability and reinforces concerns about the concentration of power.” That, in turn, bolsters arguments from EU agencies and legal commentators that MiCA’s decentralization exemption must be interpreted narrowly, with regulators focusing on where effective decision-making and operational control actually sit, rather than on marketing language about DAOs.

In practice, the ECB’s approach signals that supervisors are ready to treat DeFi governance structures with the same forensic scrutiny applied to large banks’ shareholder registers and control chains. If Aave, Uniswap or MakerDAO cannot demonstrate materially dispersed and accountable governance, their DAOs may be forced into the same kind of licensing, capital, and compliance obligations now facing centralized crypto-asset service providers across the bloc.

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Crypto World

Incentive Design Could Change Retail Investors’ Fortunes

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Talos Extends Series B to $150M with Robinhood, Sony Backing

Opinion by: Ilya Tarutov, founder of Tramplin

Crypto hasn’t struggled because the technology was flawed. Instead, it faltered as a result of the incentive structures the industry created, which have quietly turned it into something that works against the very people it was supposed to serve.

Since 2017, every crypto market cycle has followed the same pattern. Each cycle started with excitement, followed by retail inflows, a velocity trap and catastrophic drawdowns, and ended in an erosion of trust that takes months, if not years, to rebuild. Each cycle begins with optimism, peaks at overconfidence and concludes with panic and despair.

Most of the time, crypto users are quick to blame market conditions, macro headwinds and regulation. Yes, they’re important factors. What actually determines outcomes, cycle after cycle, is how the incentives are designed.

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Crypto loses everyday users because the system quietly pushes them to take the biggest risks. This begins with psychology: Traders often adopt the mindset that “the higher the return desired, the greater the risk required.”

A small token balance earning just a fraction of a percent through staking doesn’t feel like real progress. Yes, the staking market surpassed $245 billion, but platforms generally offer 2%-10% APY, which, for balances of a couple thousand dollars or less, might yield less than $100 in annual profits. 

Meanwhile, take derivatives platforms. They provide their users sophisticated and high-leverage trading opportunities and processed a record $85.7 trillion in trading volume in 2025.

“Just stake” isn’t enough anymore

Native staking is straightforward and relatively safe; rewards come directly from the network itself. Staking alone doesn’t fix the deeper problem. The platforms built around it still promote speculation, high leverage, trading driven by FOMO and risky looping strategies.

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What retail investors need is a way to participate without constant exposure to risk or serving as exit liquidity for faster, better-informed market players. 

Related: Hybrid governance program gives tokenholders a voice on this platform

What’s the solution? Creating a savings product with capital preservation as a core design goal.

The “savings layer” concept

A crypto savings layer needs to be built around a clear set of rules. These principles are non-negotiable, as they have a great, positive influence on user behavior. Examples of this include capital preservation, full transparency and rewards for discipline over speed or speculation. The savings layer should also work just as well for a 10-USDt (USDT) balance as for a 100,000-USDt one. 

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The “real” world already offers products designed around trust and capital preservation, rather than speculation.

Consider the United Kingdom’s Premium Bonds. They don’t promise high fixed yields. What they do is preserve your capital while giving you a chance at prizes.

According to NS&I, 71,722,056 prizes were paid out in 2025, totaling 4.95 billion pounds ($6.6 billion), with over 470,000 new accounts opened and eligible Premium Bonds holdings growing to 134.6 billion pounds.

Yes, it is not a blockchain product. It’s a well-designed savings program. The lesson is still simple: There’s a reason to participate, you understand how it works and your money stays safe.

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In the United States, prize-linked savings has gained traction for similar reasons. This kind of incentive layer makes it easier for people to build consistent saving habits.

The mechanics of a “saving layer concept” in crypto must be simple enough to explain in one or two sentences. 

If a person can’t explain in plain terms to their friends where their rewards come from, that means the design isn’t transparent enough. Whether rewards are generated from transparent sources or from a clearly defined chance-based model, the system must be honest about what it can offer people, and what it cannot. 

The most crucial aspect is that incentives must work even with small balances. The system must reward consistency over speed, and discipline over speculation, so that staying involved matters more than getting in early.

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Just as important is what the system should not do. Destructive risk shouldn’t be the default option, as the goal is to minimize losses, keep users in profit and encourage long-term participation. 

That is what a savings layer actually means: a system designed to help everyday users stay in the game, not one that quietly pushes them out.

Rewriting the system

If the next cycle doesn’t introduce ways to protect everyday users, they will keep experiencing crypto as a story that always ends the same way: big hype, big promises and painful collapses.

What needs to change is not the technology but what the technology is optimized for. Products must be built to reduce losses, not to maximize turnover. These changes must take place now, unless industry players want to repeat the same mistakes over and over again.

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Crypto’s future comes down to a single choice: protect everyday users or keep optimizing for short-term gains. Only one of those leads somewhere worth going.

Opinion by: Ilya Tarutov, founder of Tramplin.