Tokenized deposits vs stablecoins: what is the difference?
A tokenized deposit is a bank deposit recorded on a ledger, bound to the account holder and covered by deposit protection; a stablecoin is a token that passes from holder to holder, backed by a reserve and without deposit protection. A bank may issue both.
Tokenized deposits and stablecoins in brief
| Terms | Tokenized deposit, German: tokenisierte Einlage. Stablecoin, in EU law an e-money token, German: E-Geld-Token. |
|---|---|
| Legal sources | Deposits: Directive 2014/49/EU and the bank rules CRD and CRR. E-money tokens: Title IV of Regulation (EU) 2023/1114 (MiCA). |
| Applies since | MiCA rules for e-money tokens since June 30, 2024 (Article 149). |
| Supervisors | BaFin in Germany, FMA in Austria, FINMA in Switzerland. |
| Market | One live tokenized deposit case in the European Economic Area (EBA, December 2024); euro stablecoins authorized under MiCA around EUR 395 million (ECB, November 2025). |
What is the difference between tokenized deposits and stablecoins?
The difference between tokenized deposits and stablecoins is the claim. A tokenized deposit is a deposit at one bank, tied to a client relationship. A payment to another bank destroys the claim at the sender's bank and creates one at the receiver's bank. A stablecoin circulates from wallet to wallet, and the issuer's balance sheet changes only at redemption (EBA, December 2024).
| Feature | Tokenized deposit | Stablecoin (e-money token) |
|---|---|---|
| Issuer | Credit institution | Credit institution or e-money institution (MiCA Article 48) |
| Claim | Deposit claim on the bank | Claim on the issuer, redeemable at par at any time (Article 49) |
| Transfer | Bound to the account holder | Passes between holders like a bearer instrument |
| Backing | The bank's balance sheet under capital and liquidity rules | Reserve with at least 30 percent in bank deposits (Article 54) |
| Deposit protection | Yes, EUR 100,000 per depositor and bank | No (Article 51(4)) |
| Interest | May be paid | Banned (Article 50) |
Are tokenized deposits stablecoins?
No, tokenized deposits are not stablecoins. A tokenized deposit stays a deposit, and MiCA excludes deposits from its scope (Article 2(4)). A stablecoin is a crypto-asset under MiCA. The two are hard to tell apart at times: supervisors told the EBA that it can be "challenging to differentiate between a sight deposit that pays no interest and e-money issued by a credit institution". The EBA therefore lists features for a case-by-case test.
Some banks use the name deposit token. J.P. Morgan calls its product a "deposit token"; the EBA report notes the term and does not go into how deposit tokens differ from tokenized deposits.
Which one may a bank issue?
A bank may issue both. Tokenized deposits fall under its banking license, because recording a deposit on a ledger does not change what a deposit is, in the EBA's reading. For an e-money token, a credit institution needs no second license, but it must notify and publish a crypto-asset white paper (MiCA Article 48(1)). In the interim MiCA register of the European Securities and Markets Authority, four credit institutions appear among the issuers of e-money tokens in the update of September 24, 2026. The issuers of each type are described on what are stablecoin issuers?
What happens if the issuer fails?
If a bank fails, the deposit guarantee scheme repays tokenized deposits like any other deposit: up to EUR 100,000 per depositor and bank, within seven working days (Articles 6(1) and 8(1) of Directive 2014/49/EU). If a stablecoin issuer fails, no deposit guarantee applies. Holders depend on the reserve: the issuer keeps a redemption plan that pays holders from the sale of the remaining reserve assets (MiCA Article 47, applied to e-money tokens by Article 55). The rules for the reserve are on what are stablecoins backed by?
What does the BIS say about the singleness of money?
The Bank for International Settlements (BIS) says tokenized deposits protect the singleness of money better. Its 2023 bulletin "Stablecoins versus tokenised deposits: implications for the singleness of money" finds that stablecoins as bearer instruments "may entail departures in their relative exchange values away from par". Tokenized deposits "that do not circulate as bearer instruments but rather settle in central bank money are more conducive to singleness" (BIS Bulletin 73, April 11, 2023). The ECB added in 2026 that tokenized commercial bank deposits "may in time prove preferable to stablecoins for many wholesale use cases" (ECB, May 8, 2026).
Tokenized deposits vs stablecoins in Germany, Austria and Switzerland
| Country | Tokenized deposit | Stablecoin |
|---|---|---|
| Germany | KWG; protection EUR 100,000 (section 8 EinSiG); BaFin | MiCA, KMAG and ZAG; BaFin |
| Austria | BWG; protection EUR 100,000 (section 7 ESAEG); FMA | MiCA and MiCA-Verordnung-Vollzugsgesetz; FMA |
| Switzerland | Banking Act; protection CHF 100,000 per client and bank (esisuisse); FINMA | Swiss law, no MiCA; claims usually deposits under banking law or collective investment schemes (FINMA); FINMA |
In Switzerland the two can coincide: FINMA writes that stablecoin claims "are usually categorised as deposits under banking law" when the issuer manages the assets for its own account and risk (FINMA, July 26, 2024).
In Europe, the ECB in Frankfurt runs the link between DLT platforms and central bank money. On September 21, 2026, it launched Pontes, the Eurosystem service that links market DLT platforms with TARGET Services, so that DLT-based wholesale transactions settle in central bank money (ECB, Pontes).
This page gives no legal advice.
Sources
- European Banking Authority: Report on tokenised deposits, EBA/REP/2024/24, December 2024
- Bank for International Settlements: Stablecoins versus tokenised deposits: implications for the singleness of money, BIS Bulletin 73, April 11, 2023
- European Central Bank: Stablecoins and the future of money: separating functions from instruments, speech by Christine Lagarde, May 8, 2026
- European Central Bank: Stablecoins on the rise: still small in the euro area, but spillover risks loom, Financial Stability Review, November 2025
- European Central Bank: Pontes, read September 29, 2026
- European Union: Regulation (EU) 2023/1114 on markets in crypto-assets, May 31, 2023
- European Union: Directive 2014/49/EU on deposit guarantee schemes, April 16, 2014
- European Securities and Markets Authority: Interim MiCA register, update of September 24, 2026
- Germany: Einlagensicherungsgesetz (EinSiG), section 8, read September 29, 2026
- Austria: Einlagensicherungs- und Anlegerentschädigungsgesetz (ESAEG), BGBl. I Nr. 117/2015
- esisuisse: Swiss deposit insurance, read September 29, 2026
- FINMA: Guidance 06/2024, Stablecoins: risks and challenges for issuers of stablecoins and banks providing guarantees, July 26, 2024
About Finance Loop: tokenized deposits and stablecoins
Finance Loop is the meeting place for people in treasury and digital assets at banks who decide between putting deposits on a ledger and issuing an e-money token. It connects the finance, IT and AI communities in Frankfurt, where the ECB launched Pontes on September 21, 2026, to settle DLT transactions in central bank money.
Venturebloxx and Finance Loop are preparing the institutional report The Future of Money in Europe on stablecoins, tokenized deposits and CBDCs. One of its questions is how banks will compete with stablecoin issuers. Contributors include J.P. Morgan Kinexys, Commerzbank and Monerium.