A European Central Bank paper examining four major DeFi protocols found that more than 80% of governance token supply sits with the top 100 holders in each network, undercutting claims that DAOs deliver distributed control.

ECB Working Paper No. 3208 analyzed governance at Aave, MakerDAO, Ampleforth and Uniswap using on-chain data from October 2022 and May 2023. Researchers reviewed 248 governance proposals, the top 100 token holders and the top 20 voters per protocol.

How concentrated is governance?

At Aave and Uniswap, the top five holders accounted for roughly half of all tokens. MakerDAO posted the lowest concentration among the four, with its top five controlling about 36%. Distributions barely shifted between the two snapshots.

Protocol-associated addresses — covering treasuries, founders and developer allocations — held 43% of Uniswap's UNI supply. Centralized exchange wallets accounted for 16% at Aave and 19% at Ampleforth. Binance emerged as the dominant exchange holder across all four protocols, with positions ranging from 2% to 15% of total supply.

The authors flagged a data limitation: blockchain records cannot distinguish exchange-held assets from custody balances for customers.

Who actually votes?

Delegates — entities that aggregate voting power from smaller holders — drove active governance across all four protocols.

• Andreessen Horowitz's crypto unit was the top Uniswap voter in both snapshots; its delegator count grew from 100 to 125 over the study window.
• Aave's own smart contracts held the top-voter position.
• Uniswap posted the highest delegation rate at 27%, with its top 18 voters controlling more than half of delegated power.

Of 68 top voters identified across protocols, researchers could not determine identities for between one-third and nearly half. Among identified voters, individuals made up about 21% and Web3 companies about 19%, followed by university blockchain societies and venture capital firms.

What did governance actually decide?

The team categorized the 248 proposals reviewed. Risk-parameter changes — loan-to-value ratios, liquidation thresholds, borrowing rates and debt ceilings — accounted for 28%, the largest category. Asset-listing proposals followed at 23%.

What does this mean for MiCA?

The findings land inside an active regulatory debate. The EU's Markets in Crypto-Assets regulation exempts services provided in a "fully decentralized manner." The ECB team argued the four protocols fall well short of that threshold.

"It is not always clear who in the end is responsible or can be held accountable based on publicly available data," the authors wrote.

The paper drew parallels to corporate shareholder governance, where low turnout and outsized influence by recurring participants shape outcomes. DeFi, however, lacks the proxy voting rules, disclosure requirements and fiduciary duties that constrain behavior on public-company boards.

The authors concluded that governance token holders, protocol developers and centralized exchanges have each been proposed as regulatory entry points — yet the opacity of on-chain control makes all three difficult to use in practice. As DAOs adopt formal legal wrappers, the paper suggested hybrid structures integrating traditional legal frameworks with on-chain governance may be needed.

The research arrives as governance disputes roil Aave, where figures within the DAO have publicly challenged Aave Labs' stewardship, and as Balancer weighs dismantling its development-company arm. EU regulators now have quantitative ammunition to argue that the MiCA "fully decentralized" carve-out applies to a narrower set of actors than the industry has assumed.