Stablecoins and Tokenized Deposits: Two Claims Not to Be Confused

Two tokens may display the same reference value and operate in a programmable environment without granting the same rights. This distinction becomes important with blockchain payment projects. The term “tokenized” describes a way of representing and transferring value; it does not by itself indicate who must repay the holder or under which regime.

The deposit remains a claim on the bank

In its December 2024 report on tokenized deposits, the European Banking Authority explains that recording a deposit claim on a distributed ledger, instead of a traditional register, does not in itself change its fundamental nature. In this narrow sense, the client retains a claim on the credit institution. The change of technology is therefore insufficient to create a new legal category.

One must nevertheless verify that the structure examined truly matches this definition. A commercial name, a familiar interface, or a token expressed in euros does not replace the examination of the underlying obligations. The EBA specifically stresses the need for a coherent approach to classification and for monitoring the various use cases. All digital representations of a balance must not be grouped together without analysis.

MiCA draws this line: its Article 2 excludes from its scope crypto‑assets qualified as deposits, including structured deposits. An instrument that falls within this category must therefore be distinguished from an electronic money token subject to the regulation. This exclusion does not mean an absence of regulation.

Programmability does not make the instruments interchangeable

In its payment strategy published on 31 March 2026, the Eurosystem envisages several settlement assets: central bank money, tokenized bank deposits and properly designed and regulated stablecoins. It presents these forms as complementary, each with different legal and prudential characteristics. Technical possibilities do not erase the separation between public money and private obligations.

Circulation is a concrete difference. The ECB notes that certain forms of tokenized deposits can only be held by customers of the issuing bank. Their reach then depends on the connections that allow settlements between institutions. A token that is technically transferable and a payment that is economically accessible to all recipients are two different things.

Consider a hypothetical case: a company pays a supplier with a deposit represented on a shared ledger. One must know whether the supplier can receive that claim directly, whether they must become a client of the same bank, or whether a conversion takes place. Describing only a “blockchain” transaction would leave these essential steps in the dark.

Compare the rights before comparing the speed

An analysis of a service should start with the identity of the issuer, the nature of the claim, and the modalities for redemption into bank money. It should then specify who can hold the instrument, how it moves from one institution to another, and which intermediaries ensure its custody. These questions determine the actual functioning of the payment.

IT security and ledger availability also need to be examined: a proper legal qualification does not eliminate operational incidents. Conversely, a fast technical demonstration does not establish the extent of the holder’s rights. The debate on tokenized payments therefore benefits from comparing precisely defined instruments rather than labels or generic promises of modernization.