ECB: Aave, Uniswap, and MakerDAO Too Centralized for MiCA

The European Central Bank has published a working paper questioning the decentralization of four major DeFi protocols. According to the March 26 study, governance of Uniswap, Aave, MakerDAO (now Sky), and Ampleforth is excessively concentrated - the top 100 addresses in each protocol control over 80% of governance tokens.

What the study found

The ECB analyzed the distribution of governance tokens across four protocols using on-chain data. The results revealed systemic concentration: a significant share of tokens belongs to the protocols themselves or is held on centralized and decentralized exchanges. Among centralized platforms, Binance was identified as the largest holder of tokens across all four projects.

Voting is even more concentrated

If token distribution already raises concerns, actual voting patterns reveal even greater concentration. In Ampleforth, just 20 most active participants control 96% of delegated voting power. In MakerDAO, the top 10 voters hold 66%, while in Uniswap 18 addresses control 52%.

The situation is complicated by the fact that key voting participants are often authorized representatives - delegates, rather than direct token holders. Moreover, the identities of these delegates are mostly not publicly disclosed, making identification impossible. For regulators, this is a deep problem: you cannot oversee what you cannot identify.

Threat to the MiCA exemption

The MiCA (Markets in Crypto-Assets) regulation, now fully effective in the European Union, exempts "fully decentralized" services from licensing requirements. This exemption was a compromise: the EU acknowledged that regulating truly decentralized networks is impractical. But the ECB study questions whether these protocols actually meet this criterion.

If Aave, Uniswap, or MakerDAO cannot demonstrate substantially dispersed and accountable governance, their DAOs will be required to obtain official authorization as crypto-asset service providers. This means strict capital requirements, corporate governance standards, compliance obligations, and consumer protection measures - the same rules that already apply to centralized exchanges.

Industry reaction

The study has sparked lively debate among developers and investors. Proponents of decentralization point out that protocols have significantly improved their governance mechanisms since the data was collected. MakerDAO underwent a major restructuring under the Sky brand, while Uniswap launched updated vote delegation mechanisms that broadened its participant base.

At the same time, critics acknowledge the problem is real. Even with formally distributed tokens, actual decision-making often remains in the hands of a small group. This resembles the situation in traditional public companies where small shareholders rarely vote - but regulators may use precisely this parallel as an argument for licensing.

Implications for DeFi and the crypto market

The ECB working paper is a signal, not a final decision. The next step will be the publication of ESMA (European Securities and Markets Authority) guidelines on defining "full decentralization" for MiCA purposes. These guidelines are expected in the second half of 2026 and will determine the fate of dozens of DeFi protocols.

For the Ethereum ecosystem, where most of the mentioned projects operate, this could be a turning point. If the EU introduces strict decentralization criteria, it will set a precedent for other jurisdictions and force DeFi to rethink its governance models, or accept regulatory frameworks on par with traditional financial institutions.