Regulatory Responses to the Financial Stability Implications of Stablecoins (Ulrich Bindseil)
Ulrich Bindseil posted a paper that examines the regulatory and financial stability implications of stablecoins, framing them as electronic money issued by narrow balance sheet entities onto programmable platforms. He highlights that European, U.S and U.K. regulatory approaches aim to prevent stablecoins from destabilizing the financial system, but the rules on what assets must back stablecoins diverge widely, with the U.S. favoring short-dated Treasury bills, the EU requiring bank deposits, and the U.K. preferring central bank deposits. However, all insist that stablecoins must not pay interest, a legacy from the era of paper money that does not make sense for electronic assets. The rationale appears to be protection of banks from excessive competition, based on supposed positive externalities from deposit creation and lending, yet the author argues that non-remuneration is a blunt instrument, not a well-designed response to any market failure. Opportunity costs for stablecoin holders rise with interest rates, triggering shifts to other assets, while issuers still earn intermediation margins. The author proposes that better-targeted regulation can address risks and market failures without unnecessarily distorting incentives or relying on mechanical non-remuneration, thus calling for more nuanced policy approaches. For example, Ulrich suggests targeted regulatory charges levied on stablecoin issuers, designed to offset any negative externalities or to compensate for positive externalities lost when funds flow out of banks toward stablecoins. [Source SSRN]
Draft Digital Euro Legislation Prioritizes Offline Payments (European Parliament)
It is notable that the European Parliament’s draft digital euro legislation prioritizes the rollout of the offline version. It mandates that the European Central Bank (ECB) complete all technical and organizational preparations for the offline digital euro before the online version is considered. Introduction of the online digital euro will depend on a market assessment by the European Commission, which will proceed only if there is no suitable pan-European private retail payment solution that covers person-to-person, point-of-sale, and e-commerce. Both forms, upon ECB authorization, enter a minimum 24-month adaptation phase to allow payment service providers and stakeholders to adjust securely and gradually. This framework aims to avoid crowding out private sector solutions, synchronize technical standards, and ensure interoperability, with clear fee guidelines and user choice, making public sector intervention conditional and proportional to actual market needs. [Source: European Parliament]
The draft legislation also requires that offline transactions resemble the anonymity of physical cash. Payments are conducted directly between devices, without reliance on central infrastructure, so payment service providers do not process or record any personal data linked to individual transactions. Only minimal information needed for funding or defunding the device—such as device identifiers—is handled, and no monitoring or tracking of payment activity occurs during offline use. Robust safeguards will be required to prevent the identification of users through device registration, mandating that only the data strictly necessary for regulatory compliance is processed and never used for profiling or tracing specific transactions. As a result, offline digital euro payments would be highly privacy-preserving, ensuring that personal information and payment details remain outside the access of both authorities and service providers.
Upcoming Speaking Engagements:
The Cedi@60 Anniversary Currency Conference (Accra, Ghana, November 17-20) hosted by the Bank of Ghana, in partnership with Currency Research, will celebrate 60 years of the Ghanaian Cedi, bringing together leaders from across Africa and beyond to reflect on the currency’s legacy and chart its digital future. Learn about Ghana’s eCedi pilot and the future of sovereign digital currencies in Africa, and engage with innovators driving mobile money, QR code payments, and financial inclusion across the region. [Register here and get 15% off by using the Kiffmeister15 code!]
The Digital Euro Conference 2026 (Frankfurt, March 26) will explore the future of money with a focus on CBDCs, stablecoins, and commercial bank tokens. This hybrid event offers the perfect platform to understand the future of digital money! [Register here and get 20% off the regular ticket price by using the Kiffmeister20 code!]
I produce a monthly digest of digital fiat currency (DFC) developments exclusively for the official sector (e.g., central banks, ministries of finance and international financial institution (e.g., the BIS, IMF, OECD, World Bank)) plus academics and firms that are active in the DFC space (commercial banks, technology providers, consultants, etc.). (DFCs include central bank digital currency (CBDC), stablecoins and tokenized deposits.) It goes out via email on the first business day of every month, and if you’re interested in being on the mailing list, please email me at john@kiffmeister.com.
