The European Central Bank published a working paper on March 26, finding governance in major DeFi protocols-Aave, MakerDAO, Ampleforth, and Uniswap-is heavily concentrated. Top 100 holders control over 80% of governance tokens.
While governance tokens are spread across tens of thousands of addresses, significant shares are linked to the protocols themselves or centralized exchanges like Binance. This raises questions about accountability and regulatory oversight under MiCA, which exempts fully decentralized services.

Top 20 voters in Ampleforth control 96% of delegated voting power. Even in DAO structures, voting power remains concentrated among a few participants, highlighting governance risks.
The report also notes that identifying who controls major protocols is difficult, making regulatory anchor points hard to determine. This echoes concerns from the Financial Stability Board about new forms of concentration in DeFi.