On September 24, 2026, Brussels and New York simultaneously signaled starkly different yet aligned messages to the same market: one side extended regulatory boundaries to leverage, while the other tightened monetary gates. At the EU level, the core regulatory framework for the crypto asset market, MiCA, previously focused primarily on the licensing and operational requirements for issuers and crypto asset service providers, while crypto asset lending and intermediary-facilitated crypto lending have long wandered in an unclear gray area. On that day, the EBA, in response to the European Commission's targeted consultation on MiCA, explicitly suggested for the first time to include crypto asset lending activities (including intermediary-type crypto lending) within the scope of MiCA regulation, extending regulatory oversight to scenarios where "service providers help customers access DeFi lending protocols," while requiring the European Commission to carry out a cost-benefit analysis for legislative changes and consider increasing compliance and regulatory requirements—although no specific leverage ratios, appropriateness standards, or timelines were provided, these suggestions already imply that on-chain lending will no longer be merely a technical protocol but will be regarded as a financial activity requiring institutional constraints. Almost on the same day, John Williams, the president of the New York Federal Reserve, publicly stated that U.S. inflation remains significantly above the Federal Reserve's 2% target, with energy prices and investment demand related to artificial intelligence supporting inflation, asserting that the Federal Reserve still has "a lot of work to do" regarding price control, and that the market's expectation of one more rate hike this year is a "reasonable judgment," while emphasizing that the policy path will continue to be driven by economic data, he also affirmed the "extraordinary resilience" of the U.S. economy and labor market. As the EU discusses how to incorporate crypto lending and DeFi into the regulatory framework, and while the Federal Reserve signals a continued tight monetary policy, the on-chain leverage in the crypto market finds itself at a new crossroads: one end is the gradual tightening of institutional-level regulatory gaps, bringing previously gray areas into regulation, while the other end is the macro-level pressure of high interest rates and tightening liquidity. These two forces combined are pushing crypto lending and the entire on-chain leverage structure into a phase of dual tightening, facing both regulatory constraints and funding tightness.

Regulatory Gaps: EBA Targets Crypto Lending and DeFi Entry

If the previous MiCA was more like a framework around "issuance" and "licensing," then crypto asset lending has always been an intentionally sidelined component. The core provisions of MiCA focus on issuers of crypto assets and the licensing and operational requirements for crypto asset service providers, but did not clearly outline the regulatory landscape for crypto asset lending and intermediary crypto lending, resulting in a blurred area between traditional lending and on-chain leverage. As MiCA enters its implementation phase, this gray area has neither been formally exempted nor clearly incorporated, leaving regulators and the market in a long-term ambiguous state regarding the judgment of "whether it counts as a regulated business."

This ambiguity was directly addressed by the European Banking Authority on September 24, 2026. In its response to the European Commission's targeted consultation on MiCA, the EBA explicitly recommended including crypto asset lending activities—including intermediary crypto lending—within the MiCA regulatory framework and further directing attention to the entry level of DeFi lending: any crypto asset service provider assisting customers in accessing DeFi lending protocols should, according to the EBA's vision, be regarded as part of regulated business. The regulator's logic is simple: one cannot allow actual lending and leverage activities to remain hidden outside the framework through "intermediaries" and "technical access." To this end, the EBA suggested that the European Commission undertake a cost-benefit analysis regarding relevant legislative changes and consider adding additional compliance requirements and regulatory activities for intermediary crypto lending services. However, as of publicly available information, the EBA has not disclosed any specific leverage limits, appropriateness testing standards, or implementation timelines, and it remains uncertain whether the European Commission will adopt these suggestions or when it will initiate legislative procedures; for participants in on-chain leverage, this means that from centralized lending to DeFi entry, all may be subjected to the same set of regulatory logic, with the pace of tightening depending on the European Commission's subsequent legislative choices.

Outline and Unknowns of Leverage Limits and Appropriateness Testing

In the EBA's response document, the key terms for future toolkits have been identified—on one end, setting "leverage limits" for crypto lending, and on the other, conducting "appropriateness testing" for investors. This sketches a general direction: regulators are no longer solely focused on whether platforms are licensed or how assets are custodied, but are directly intervening in “how much leverage can be taken on, and who is eligible for leverage” as two core variables. However, to date, there is no public information on specific ratios, risk grading models, or testing questionnaire templates, nor any implementation timeline; whether the European Commission will adopt these ideas remains uncertain, leaving the market to infer possible tightening paths from these vague outlines, yet unable to quantify them into hedgeable policy risks.

In terms of object scope, the EBA clearly pointed its focus toward intermediary crypto lending services and crypto asset service providers that assist customers in accessing DeFi lending protocols. Once the MiCA regulatory framework extends according to this recommendation, these intermediaries will no longer simply be "channels," but must accept the added compliance requirements and regulatory activities. For them, the future may not only involve proving their own risk control capabilities, but they will also need to record and explain the leverage levels and risk tolerances of their clients; for participants in on-chain leverage, both centralized lending platforms and DeFi entry could be included within the same regulatory narrative. More critically, the EBA has recommended that the European Commission undertake a cost-benefit analysis regarding legislative changes. Only after this step is completed and a political consensus is formed will it become clear whether any actual legislation will follow, and when it will be implemented; thus, the current leverage limits and appropriateness testing within the EU remain in the stage of policy expectation rather than executable rules.

From Trading to Credit: The Extension of EU Regulatory Boundaries

Within the existing framework of MiCA, the EU's focus on crypto assets has remained at the level of "who issues them, who provides trading and custody services," where the regulatory objects are the licenses and operations of issuers and crypto asset service providers. In this response to targeted consultations, the EBA has suggested including "crypto asset lending activities (including intermediary crypto lending)" and "activities where service providers assist customers in accessing DeFi lending protocols" within MiCA, which is essentially an expansive interpretation of existing provisions: the regulatory perspective has formally extended from circulation and trading to the credit segment both on-chain and off-chain, recognizing leverage as an independent risk source that needs to be identified and governed.

This move directly impacts the narrative long upheld by the crypto industry. In the past, "decentralized and unregulated" relied more on the fact that protocols were deployed on-chain, while front-end access, funding matching, and risk alerts mostly wandered in gray areas of MiCA. The EBA now explicitly names intermediary crypto lending and DeFi access services, demanding the European Commission assess their inclusion into the regulatory framework, increasing compliance requirements and regulatory activities, meaning that regulation does not necessarily need to directly "control the protocol," but can reshape business models through access and intermediary layers—centralized crypto lending platforms that continue to offer leverage to EU users may soon need to introduce a set of operational logic closer to traditional finance in areas like credit pricing, risk disclosure, and customer segmentation; while service providers acting as DeFi entry points must choose between a "pure technical interface" and "regulated credit intermediary," each path will reshape their growth narratives and risk boundaries.

Federal Reserve's Hawkish Stance: The Collision of Macroeconomic Liquidity and On-Chain Leverage

As the EU redefines leverage boundaries from the access level, the signals from the U.S. suggest that money will no longer be as cheap. John Williams, president of the New York Federal Reserve, spoke on the same day, stating that U.S. inflation remains significantly above the Federal Reserve's 2% target, with high energy prices and investment related to artificial intelligence driving demand, continuing to support inflation. In his view, the Federal Reserve "has a lot of work to do" in controlling prices, and the market considers it a "reasonable judgment" that there will be another rate hike before the end of the year, but the ultimate path will still depend on the evolution of data regarding the economy and employment—currently, the resilience displayed by the U.S. economy and labor market is indeed "extraordinary."

This narrative translates to the crypto world, indicating an environment with tighter dollar liquidity and higher funding costs is becoming the baseline scenario. For centralized crypto lending platforms, with the U.S. interest rate curve moving upward, wholesale financing costs and user borrowing rates will inevitably rise, and high-leverage accounts are more likely to trigger a chain of forced liquidations under margin pressure; floating rates in DeFi lending protocols will also passively increase when external yields rise, leading to the withdrawal of arbitrage funds and a cooling of risk appetite, pushing on-chain leverage from "seeking returns" to "defending liabilities." As the EU tightens compliance space for crypto lending on the institutional level, and the Federal Reserve tightens the monetary liquidity valves on the macro level, these two previously unrelated policy lines are forming a cumulative effect at the intersection of on-chain leverage: any new rate hike expectations or data surprises could amplify the vulnerabilities in on-chain funding structures, making the crypto market more clearly expose the true costs of leverage in the next round of fluctuations.

Compliance Intermediaries and DeFi Iteration: The Next Chapter of Crypto Lending

Under the dual pressure of the EU filling regulatory voids and the U.S. tightening monetary conditions, crypto lending and on-chain leverage appear to be "caged," yet are also being pushed toward a window of compliance-driven restructuring: those who can rewrite the rules within constraints have the opportunity to become the infrastructure for the next cycle. As of September 24, 2026, the EBA's recommendations remain at the consultation and policy suggestion stage, and it is unclear whether the European Commission will adopt and initiate legislative changes; however, the regulatory boundaries have pointed toward a clear direction—there may soon emerge specialized "regulated crypto credit intermediaries" that, while meeting the licensing and operational requirements under MiCA, provide compliant access points for institutions and individuals to DeFi lending protocols, redefining the blurred roles and responsibilities from the past decentralized world. Meanwhile, John Williams emphasizes that the policy path will depend on economic data performance, meaning that whether the Federal Reserve will raise rates will continue to be anchored to indicators such as inflation and employment, with the on-chain funding environment subject to repricing with each data release. For investors, the next chapter of crypto lending will no longer just be a story of yield curves but a narrative woven by regulatory texts and macro reports: closely tracking the EU's legislative progress around the EBA recommendations, and the Federal Reserve's policy direction driven by data, will become prerequisite conditions for assessing leverage risk positions and the tightness of the funding environment.

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