Stablecoins vs Tokenised Deposits: Why EU Money Rules Matter
Two digital euros can look alike yet offer very different protection. A Banca d’Italia paper compares stablecoins and tokenised deposits, exposing the legal and liquidity differences that emerge when holders demand repayment. For EU financial firms, the crucial question is not the technology, but who stands behind the digital money.
Frankfurt, Germany
Oct 9, 2026
A euro on a blockchain is not necessarily the same claim as a euro in a bank account. Both may be used to make payments, and both may promise a stable value. But when holders want their money back, the technology matters less than the institution responsible for repayment—and the protections supporting that promise.
That distinction anchors Banca d’Italia Occasional Paper No. 1062, in which Giuseppe Ferrero and Federico Guerra compare electronic money tokens with tokenised bank deposits. Their economic assessment puts a familiar regulatory principle at the centre of Europe’s developing digital-money market: “same activity, same risk, same regulation.”
The question is not whether every instrument on a distributed ledger should face identical rules. It is whether differences in regulation reflect genuine differences in risk—or create incentives to package similar monetary promises in whichever legal form is most convenient.
One currency, different claims
The EU’s Markets in Crypto-Assets Regulation, or MiCA, defines an electronic money token, or EMT, as a crypto-asset that purports to maintain a stable value by referencing one official currency. A euro-denominated stablecoin meeting that definition falls into a specific regulatory category, rather than a general class of blockchain-based money.
Under MiCA, an EMT issuer must be authorised as either a credit institution or an electronic money institution. Holders have a claim against the issuer, and Article 49 requires issuance at par value upon receipt of funds and redemption at any time, at par value. Article 50 prohibits issuers from granting interest on EMTs; it also prohibits crypto-asset service providers from granting interest when providing services related to them.
A tokenised deposit starts from a different legal foundation. It is a bank deposit represented or transferred through distributed-ledger infrastructure. MiCA excludes deposits from its scope, including structured deposits, so using blockchain technology does not by itself turn a bank liability into an EMT.
Nor does the absence of a dedicated EU tokenised-deposit regime leave these instruments outside regulation. Banking supervision, capital and liquidity requirements, deposit law and other applicable obligations remain relevant. The critical question is whether the arrangement genuinely preserves a deposit claim, not whether its developer calls it a deposit.
Ferrero and Guerra distinguish between registered and bearer-like structures. A registered tokenised deposit, linked to an identified customer and recorded as a bank liability, behaves economically much like a conventional deposit. A bank-issued EMT, they argue, is economically equivalent to a bearer tokenised deposit. That comparison concerns the instruments’ economic characteristics; it does not make their legal protections interchangeable.
The real test is redemption
A payment token can circulate smoothly while confidence is high. Its resilience becomes clearer when many holders seek redemption simultaneously.
The paper identifies particular vulnerabilities in EMTs issued by electronic money institutions. These institutions do not have the direct access to central-bank balance sheets and standing facilities available to eligible banks. Their ability to meet a surge in redemptions therefore depends on different liquidity resources and arrangements.
The Electronic Money Directive requires electronic money institutions to safeguard funds received in exchange for electronic money. MiCA adds requirements governing funds received for EMTs. Those protections matter, but safeguarding assets is not the same as having immediate access to cash in a stressed market.
An issuer may hold assets intended to support repayment and still face difficulty converting them into money quickly enough. If holders doubt that redemption will be prompt and reliable, a token can trade below its stated value even while the legal right to redeem at par remains intact. The distinction between a repayment promise and the capacity to honour it is central to run risk.
Banks are not immune to that problem. Their liquidity support is conditional, and central-bank access is not an unlimited guarantee against failure. Nevertheless, prudential supervision, liquidity requirements, resolution arrangements and deposit protection give bank deposits a different institutional foundation.
For holders, one particularly important distinction is that EMTs do not receive deposit-guarantee protection simply because a bank issues them. MiCA requires EMT white papers to warn that the tokens are not covered by deposit-guarantee schemes. By contrast, a qualifying bank deposit can fall within the EU Deposit Guarantee Schemes Directive, which generally protects eligible deposits up to €100,000 per depositor per bank. Whether a tokenised product qualifies depends on the underlying claim and applicable eligibility rules.
Why the boundary matters for the euro
These differences reach beyond the fortunes of an individual issuer. They bear on the singleness—or “unicity”—of money: the expectation that a euro retains the same value across the forms and institutions through which it circulates.
In the established banking system, confidence in that equivalence rests on more than a common currency label. It is supported by settlement arrangements, supervision, liquidity backstops and protection for eligible depositors. A token displaying “EUR” does not automatically reproduce that architecture.
If widely used tokens begin trading at different discounts during stress, users may have to assess the creditworthiness and liquidity of each issuer before accepting payment. The resulting fragmentation would weaken the practical usefulness of money, even if every token continued to reference the same official currency.
Ferrero and Guerra also connect the regulatory comparison to monetary-policy transmission. Different forms of private money can react differently to funding pressures, changes in interest rates and shifts in confidence. As token-based payments expand, those differences become relevant to central banks as well as product designers.
For banks and payment firms, the practical lesson is to establish the legal claim before choosing the ledger. Who owes repayment? Can the claim move independently of an identified customer relationship? What assets support redemption, and how quickly can they be mobilised? Which protections survive if the issuer fails?
The answers determine more than compliance costs. They determine whether a digital instrument can reliably perform the monetary function its users expect.
Banca d’Italia’s comparison makes a case for examining that substance rather than treating either the token label or the banking label as decisive. Similar functions deserve comparable scrutiny, while materially different risks may justify different safeguards. Faster transfers are useful; dependable redemption is what makes the instrument credible as money.
The paper is an economic assessment, not a change to EU law. Its publication details and paper-specific findings are drawn from the supplied source material and have not been independently verified.