Buyer's guideStablecoin Studio

Tokenised deposits or a stablecoin? A decision guide for bank treasury and payments teams

A tokenised deposit and a fully reserved stablecoin can look identical in a wallet, yet one is a deposit liability of the bank and the other is a claim on a separately reserved issuer. That difference decides which law applies, whether interest may be paid, how the balance sheet is affected and who can hold the token. This guide compares the two on the criteria that matter to a bank and shows where Stablecoin Studio fits in each.

Reviewed 10 October 2026 6 min read

On this page

Two instruments, one wallet balance, different legal claims
Tokenised deposit or fully reserved stablecoin, criterion by criterion
Minting on deposit and burning on withdrawal
Which instrument fits which use case
Questions to settle with counsel, treasury and the supervisor
Where Stablecoin Studio fits in each model
Questions and answers
Sources

Two instruments, one wallet balance, different legal claims

When a bank tokenises a deposit, the customer still holds a deposit. The ledger entry is a new way of recording and moving an existing liability of the bank, so banking law, the bank's capital and liquidity rules and, where it applies, deposit insurance continue to govern it. The bank can lend against that funding in the ordinary way.

A fully reserved stablecoin is a different promise. The holder has a claim on the issuer, which must keep reserve assets equal to the tokens outstanding and redeem at par. In the EU that issuer may be a bank or an e-money institution issuing an e-money token under MiCA; in the US it may be a permitted payment stablecoin issuer under the GENIUS Act. Either way the reserves are ring-fenced rather than lent out, and the token sits under rules written for stablecoins rather than for deposits¹³.

The Bank for International Settlements has drawn the same line from a monetary angle. Its 2025 annual report chapter on the future monetary system argued that stablecoins struggle with singleness, elasticity and integrity, and pointed instead to tokenised commercial bank money settling against tokenised central bank reserves on a shared ledger⁴. A bank does not have to accept that view to see why supervisors treat the two instruments differently.

Tokenised deposit or fully reserved stablecoin, criterion by criterion

Criterion	Tokenised deposit	Fully reserved stablecoin
Legal nature	A deposit liability of the issuing bank, recorded on a ledger	A claim on the issuer, backed by segregated reserve assets
Regulatory perimeter	Banking law; MiCA does not apply to crypto-assets that qualify as deposits¹	MiCA e-money or asset-referenced token rules in the EU; GENIUS Act payment stablecoin rules in the US¹³
Holder protection	Deposit insurance where the deposit qualifies under the local scheme, plus the bank's prudential regulation	Reserve segregation and a statutory redemption right; payment stablecoins are defined so as not to be deposits³
Interest	Can pay interest like any other deposit	Interest to holders prohibited for e-money tokens under MiCA and for US payment stablecoins¹³
Balance sheet	Funding stays on the bank's balance sheet and can support lending	Reserves are held in high-quality, liquid assets and cannot be lent out
Prudential treatment	Generally treated as the underlying deposit; confirm with the supervisor	Banks' exposures follow the Basel cryptoasset standard, which treats stablecoins and tokenised traditional assets separately⁵
Who can hold it	Usually the bank's own onboarded customers, in a closed loop	Anyone the issuer permits, potentially in open circulation across wallets
Moving value to another bank	Needs interbank settlement, ideally in central bank money, or a shared ledger between banks	Moves peer to peer on the network; the receiving bank holds a claim on the issuer

Summaries are qualitative and jurisdiction-neutral. Deposit insurance, capital and liquidity treatment must be confirmed with your supervisor and counsel for the specific product.

Minting on deposit and burning on withdrawal

In a tokenised deposit, the core banking ledger stays authoritative and the token mirrors it.

Corporate customer
Holds a deposit account and a Hedera account with the KYC flag granted.
Core banking ledger
The authoritative record of the customer's deposit balance.
Token operations
The bank's service holding the cash-in and burn roles, with approval rules.
Hedera network
Records token balances and transfers between permitted accounts.

Corporate customer to Core banking ledgerrequest tokens
Core banking ledger to Token operationsdeposit earmarked
Token operations to Hedera networkcash-in to customer
Corporate customer to Hedera networkreturn tokens
Token operations to Hedera networkburn returned tokens
Token operations to Core banking ledgerrelease deposit

Conceptual message order for minting and redeeming a tokenised deposit; a reconciliation between token supply and earmarked deposits runs alongside it.

Which instrument fits which use case

If
Corporate treasury sweeps and intra-group liquidity moves among the bank's own clients.
Then
Start with a tokenised deposit in a closed loop.
Clients keep deposit status and interest, and the bank keeps the funding.
If
Cross-border business payments between clients of different banks.
Then
Prefer a tokenised deposit network shared by the banks, or a regulated stablecoin where no such network exists.
Interbank settlement is the hard part; a stablecoin removes it at the cost of a non-bank claim.
If
Retail or merchant payments in open circulation.
Then
Consider an e-money token or payment stablecoin issued by a licensed entity.
Open circulation means holders the bank has not onboarded, which deposit products are rarely designed for.
If
The cash leg of tokenised securities settlement.
Then
Use a tokenised deposit among participating banks, or a stablecoin if investors are not all bank clients; see the tokenised bond lifecycle.
Atomic delivery against payment needs both legs on ledgers that can coordinate.

Questions to settle with counsel, treasury and the supervisor

0 of 7 checked

Is the token legally a deposit in our jurisdiction?Get a written view; it determines the whole regulatory perimeter.
Does deposit insurance extend to the tokenised form?Confirm with the deposit insurer, including how a holder is identified at payout.
How will the supervisor treat it for capital and liquidity?Raise it early, citing the Basel cryptoasset standard where relevant.
Who may hold it, and can it leave our customer base?Decide whether transfers outside onboarded customers are blocked by the KYC flag.
Which ledger is authoritative if they disagree?For deposits, normally the core banking system; write it into the terms.
Public mainnet or a permissioned network?Weigh visibility of balances and counterparties against reach to other institutions.
Can we run both instruments?Possible, but they need separate terms, accounting and controls so customers know which they hold.

Where Stablecoin Studio fits in each model

The software does not decide the legal model. In both cases Stablecoin Studio gives the bank the same levers: a KYC flag per account, freeze and wipe for legal orders, separate cash-in and burn roles, multi-signature approvals and an optional reserve check before minting². For a tokenised deposit, cash-in mirrors an earmarked deposit and the core banking ledger is the reference; for a stablecoin, cash-in mirrors a credit to segregated reserves and the reserve feed is reconciled to bank statements.

Network choice follows the holder base. A closed group of corporate clients may suit a permissioned Hedera-based network such as HashSphere, keeping balances visible only to participants. Open circulation points to public mainnet. ColdAI's Stablecoin Studio work covers the treasury, signing and core-banking integration in either case, with the legal model set by your counsel.

Questions and answers

Can a tokenised deposit move to another bank?

Only if the banks have a way to settle with each other. A tokenised deposit is a liability of the issuing bank, so when a customer pays a client of another bank, the banks must settle, either through existing payment systems, through tokenised central bank reserves, or on a ledger they share. Without that, a tokenised deposit works only inside one bank's customer base.

Is a tokenised deposit a crypto-asset under MiCA?

MiCA does not apply to crypto-assets that qualify as deposits, under Article 2(4)(b), so a token that is genuinely a deposit falls under banking law instead. The recitals make clear that e-money tokens cannot be treated as excluded deposits. Whether a particular product is legally a deposit depends on its terms, so obtain a legal opinion before relying on the exclusion.

Can a bank issue both a tokenised deposit and a stablecoin?

Yes, in principle, and some banks may want both: a tokenised deposit for clients and a stablecoin for open circulation. They must be kept clearly apart, with separate terms, accounting, reserve arrangements and customer communications, so no holder confuses a deposit with a reserved stablecoin. In the EU, a bank issuing an e-money token is subject to MiCA for that token.

Do tokenised deposits pay interest?

They can, because they remain deposits and the bank sets interest under its usual terms. That is one of the clearest differences from stablecoins: MiCA bars interest on e-money tokens, and the GENIUS Act bars payment stablecoin issuers from paying interest or yield simply for holding the token. For corporate treasury use, this often decides the choice.

Sources

Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA) — EUR-Lex · checked 10 October 2026
Stablecoin Studio repository — Hashgraph on GitHub · checked 10 October 2026
The GENIUS Act: A New Federal Regulatory Framework for Payment Stablecoins — Morrison Foerster · checked 10 October 2026
Annual Economic Report 2025, Chapter III: The next-generation monetary and financial system — Bank for International Settlements · checked 10 October 2026
Prudential treatment of cryptoasset exposures — Basel Committee on Banking Supervision · checked 10 October 2026

Test your tokenised deposit or stablecoin idea against the criteria

Describe the use case, the holders and the jurisdictions. We will tell you which instrument the criteria point to, what your counsel and supervisor need to confirm, and how the token side would be built.

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