European Central Bank Paper Questions Whether DeFi DAOs Are Sufficiently Decentralized

Odaily News The European Central Bank (ECB) published a working paper on March 26, studying the governance concentration of four major DeFi protocols: Aave, MakerDAO, Ampleforth, and Uniswap. Based on snapshot data of holdings from November 2022 and May 2023, the paper found that although governance tokens are distributed across tens of thousands of addresses, the top 100 holders in each protocol control over 80% of the supply. Furthermore, a significant portion of governance tokens can be linked to the protocols themselves or to centralized and decentralized exchanges, with Binance identified as the largest centralized exchange holder across all four protocols.

Regarding voting participation, the paper points out that actual voters are primarily representatives who have obtained delegated voting power from smaller holders. The top 20 voters in Ampleforth control 96% of the delegated voting power, the top 10 voters in MakerDAO hold 66%, and the top 18 voters in Uniswap hold 52%. Approximately one-third of the major voters cannot be publicly identified.

The paper argues that these findings challenge the inherent assumption of decentralization in DAOs, making it more difficult to determine regulatory anchor points under the EU's MiCA framework. MiCA currently excludes "fully decentralized" services from its scope. The paper also notes that public data alone cannot determine whether protocol-linked holdings belong to founders, developers, or treasuries, nor can it confirm whether exchange wallets are voting for themselves or on behalf of clients. This paper represents the authors' views and does not reflect the official position of the European Central Bank.