European Central Bank document questions whether DeFi DAOs are sufficiently decentralized

On March 26, the European Central Bank published a working paper studying the governance concentration of four major DeFi protocols: Aave, MakerDAO, Ampleforth, and Uniswap.

The paper, based on holding snapshot data from November 2022 and May 2023, 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, and a large number of governance tokens can be linked to the protocols themselves or centralized and decentralized exchanges, with Binance being the largest identified centralized exchange holder among the four protocols.

In terms of voting participation, the paper noted that actual voters are mainly representatives who obtain proxy voting rights from small holders. The top 20 voters in Ampleforth control 96% of the proxy voting rights, the top 10 voters in MakerDAO hold 66%, and the top 18 voters in Uniswap hold 52%. About one-third of the main voters cannot be publicly identified.

The paper argues that these findings challenge the assumption of inherent decentralization in DAOs, making it more difficult to determine regulatory anchors under the EU MiCA framework. MiCA currently excludes "fully decentralized" services from its scope. The paper also points out that it is impossible to determine from public data whether the holdings associated with the protocols belong to founders, developers, or treasuries, nor can it be determined whether exchange wallets are voting on behalf of themselves or their clients. The paper represents the authors' views and does not represent the official position of the European Central Bank.