Stablecoin vs CBDC: what is the difference?
A stablecoin is a crypto-asset issued by a private company that promises a fixed value in a currency; a CBDC is digital money issued by the central bank itself. The stablecoin holder has a claim on the issuer, the CBDC holder a claim on the central bank. The German terms are Stablecoin and digitales Zentralbankgeld.
Stablecoins and CBDCs in brief
| Terms | Stablecoin: in EU law an e-money token (EMT) or an asset-referenced token (ART). CBDC: central bank digital currency. German: Stablecoin, digitales Zentralbankgeld. |
|---|---|
| Law for stablecoins | Regulation (EU) 2023/1114 (MiCA, also cited as MiCAR). Titles III and IV apply since June 30, 2024 (Article 149). |
| Law for a CBDC in euro | The proposed digital euro regulation, COM(2023) 369, still in negotiation. |
| Interest | Banned for EMTs and ARTs (Articles 50 and 40 MiCA). The digital euro "shall not bear interest" (Article 16(8) of the proposal). |
| Cap on use | An ART used as a means of exchange above 1 million transactions and 200 million euros a day in one currency area must stop issuance (Article 23 MiCA). |
Stablecoin vs CBDC compared
Stablecoins and CBDCs differ first in who issues the money and who stands behind it. For the euro area the two compare as follows:
| Stablecoin vs CBDC | Stablecoin (EMT or ART) | CBDC (digital euro) |
|---|---|---|
| Issuer | A private company: for EMTs a credit institution or an e-money institution | The Eurosystem |
| Holder's claim | On the issuer, backed by its reserve | On the central bank |
| Legal tender | No | Yes, under Article 7 of the proposal |
| Interest | Banned under MiCA | None under the proposal |
| Ledger | Public blockchains (BIS) | A central platform of the Eurosystem, not based on DLT |
| Status | In use; EMTs regulated since June 30, 2024 | Not issued; pilot from the second half of 2027 |
The difference between stablecoin and CBDC lies in the claim. A stablecoin holder relies on the issuer and its reserve; a CBDC holder holds a liability of the central bank.
Is a CBDC a stablecoin?
No. A CBDC is issued by a central bank, and a stablecoin by a private company. The Swiss National Bank writes that stablecoins, unlike CBDC, are issued by private companies and not by a central bank, and that most are pegged to the US dollar or the euro (SNB, CBDC).
Is the digital euro a stablecoin? No. The ECB writes that the digital euro "would be central bank money, issued and guaranteed by the Eurosystem", and that stablecoins "are not guaranteed by a central bank or public authority. Their value depends on how well the company manages its reserves and finances" (ECB, FAQ).
How does MiCA treat e-money tokens and asset-referenced tokens?
MiCA treats e-money tokens and asset-referenced tokens as crypto-assets with their own titles: Title III for ARTs and Title IV for EMTs. An EMT references the value of one official currency; an ART references another value or right, or a combination. The full definitions and examples are in What are stablecoins?
Three rules matter in the comparison with a CBDC. Issuers and crypto-asset service providers may not pay interest on either type (Articles 40 and 50). Article 23 caps an ART that is used widely as a means of exchange, and Article 58(3) applies the same cap to EMTs in a currency that is not an official currency of a member state, such as the US dollar. Recital 62 gives the reason: where asset-referenced tokens threaten "the smooth operation of payment systems, monetary policy transmission or monetary sovereignty", central banks should be able to ask for the withdrawal of the authorization.
Digital euro vs stablecoins: what does the ECB say?
The ECB says that one digital euro would always be worth one euro, while the stability of a stablecoin "is not as certain as that of the euro". The BIS applies three tests to any form of money: singleness, elasticity and integrity. In its Annual Economic Report of June 29, 2025 it finds that stablecoins "often trade at varying exchange rates, undermining singleness", and that they lack the settlement function of the central bank (BIS, June 29, 2025).
Stablecoins and CBDCs can still meet on one ledger. The BIS proposes a unified ledger with tokenized central bank reserves, tokenized commercial bank money and tokenized government bonds. The Eurosystem's Pontes, launched on September 21, 2026, settles transactions from market DLT platforms in central bank money. More on CBDC types in What is a CBDC?
Stablecoins and CBDCs in Germany, Austria and Switzerland
In Germany and Austria, MiCA applies directly to stablecoins, and BaFin and the FMA supervise their issuers. A CBDC for both countries would be the digital euro of the Eurosystem, to which the Deutsche Bundesbank and the Oesterreichische Nationalbank belong. It requires the EU regulation first.
The ECB, which would issue the digital euro together with the national central banks, has its main building at Sonnemannstrasse 20 in Frankfurt am Main (ECB, address). There is also a euro stablecoin from Frankfurt: AllUnity, owned by DWS, Flow Traders and Galaxy, received an e-money license from BaFin on July 1, 2025 and issues the euro e-money token EURAU (AllUnity, July 2, 2025).
Switzerland is outside the EU, so MiCA does not apply there. Swiss law governs stablecoin issuers, and FINMA is the supervisor. The SNB issues no retail CBDC and sees no clear advantages in one for the public. It tests a wholesale CBDC in the Helvetia pilot, which runs until at least June 2028 (SNB, Project Helvetia). This page gives no legal advice.
Sources
- European Union: Regulation (EU) 2023/1114 on markets in crypto-assets, May 31, 2023
- European Commission: Proposal for a Regulation on the establishment of the digital euro, COM(2023) 369 final, June 28, 2023
- European Central Bank: Digital euro, frequently asked questions, read on September 29, 2026
- European Central Bank: Pontes, read on September 29, 2026
- Bank for International Settlements: Annual Economic Report 2025, chapter III: The next-generation monetary and financial system, June 29, 2025
- Swiss National Bank: Will the Swiss franc soon only exist digitally?, read on September 29, 2026
- Swiss National Bank: Project Helvetia, read on September 29, 2026
- European Central Bank: Where to find us, read on September 29, 2026
- AllUnity: AllUnity secures BaFin EMI License to Launch its MiCAR compliant EURO stablecoin, July 2, 2025
About Finance Loop: stablecoins and CBDCs
Finance Loop is the meeting place for people at central banks, commercial banks and e-money institutions who weigh public against private digital money. It connects the finance, IT and AI communities in Frankfurt, home both to the ECB, which would issue the digital euro, and to AllUnity, the issuer of the euro stablecoin EURAU.
The Digital Euro Association, a strategic partner of Finance Loop, works on both: the public digital euro, a CBDC, and the private digital euro, meaning euro stablecoins under MiCA. Its Digital Money Academy has a course on each.