Stablecoins: From Niche Product to Strategic Power Instrument

Dr. Oliver Völkel, LL.M.

Dr. Oliver Völkel, LL.M.

CV | E-Mail

Bryan Hollmann, LL.M.

Bryan Hollmann, LL.M.

CV | E-Mail

From Crypto Utility to Financial Infrastructure

Few topics currently attract as much attention in the financial sector as stablecoins. What began as a technical tool within the crypto ecosystem has evolved into a strategically relevant instrument of monetary and financial policy. With the recently adopted GENIUS Act, the United States has introduced a dedicated federal framework for stablecoin issuance. In the European Union, the Markets in Crypto-Assets Regulation (MiCA), applicable since the end of 2024, provides a comprehensive regime for so-called e-money tokens (EMTs). Stablecoins have therefore moved firmly into the regulatory and geopolitical mainstream.

Stablecoins are digital value-representation tokens pegged to a fiat currency. Holders benefit from a redemption right at par value. Unlike volatile crypto-assets such as Bitcoin, stablecoins are not designed for speculation but for stability and efficient settlement. Blockchain-based transfers enable near real-time, cross-border transactions on a 24/7 basis.

Digital Dollar Dominance

The market is currently dominated by USD-backed stablecoins, accounting for more than 95% of global volume. This effectively extends the international role of the US dollar into the digital asset space. Each USD stablecoin strengthens dollar usage in global trade and financial flows, regardless of whether transactions pass through the traditional US banking system.

The Core Economic Model: Interest Margin Without Deposit Costs

The economic logic of stablecoins is striking. Issuers receive fiat funds but owe no interest to token holders. Under MiCA, the payment of interest on e-money tokens is expressly prohibited. At the same time, the reserve assets may be invested in liquid and low-risk instruments, as further specified by the European Banking Authority (EBA). In a positive interest-rate environment, this creates a structural margin effect. Stablecoins are therefore not merely payment instruments but highly efficient funding vehicles.

The European Regulatory Framework: A Fully Regulated Activity

Issuing stablecoins in Europe is not a lightly regulated FinTech exercise but a core financial services activity. A stablecoin pegged to a single official currency will generally qualify as an e-money token under MiCA. The issuer must be either a licensed credit institution or an authorized electronic money institution (EMI). For non-bank actors, this means that stablecoin issuance is effectively conditional upon obtaining an EMI license.

The authorization process is substantial. Applicants must submit a comprehensive business plan, governance framework, internal control system, IT and cybersecurity architecture, outsourcing arrangements, and robust AML/CFT policies. Detailed information on the reserve management, segregation, custody and liquidity arrangements must be provided. In addition, a white paper subject to specific disclosure requirements and liability standards must be drafted, notified to the competent authority and published.

Ongoing obligations are equally demanding. Issuers must maintain own funds, ensure daily redemption at par value, keep reserves fully liquid and segregated, and comply with extensive reporting duties. Where a stablecoin qualifies as ‘significant,’ enhanced supervision by the European Banking Authority applies, including stricter prudential and operational requirements. In practice, stablecoin issuance under MiCA resembles regulated banking activity in its structural intensity.

Strategic Structuring Considerations

Regulation also creates opportunity. MiCA provides for passporting across the EU once authorized. For international groups, the central strategic question is not whether to operate within regulation but how to structure the issuance model: through a banking license, an EMI structure, or via partnership with an existing regulated institution. Each option has different capital, governance and liability implications.

Geopolitics and Sovereign Financing

The US GENIUS Act links stablecoin issuance closely to investments in US Treasuries, thereby creating structural demand for government debt. In an era of rising public debt, this is strategically significant. Europe with MiCA has so far focused primarily on stability and investor protection. Whether euro-denominated stablecoins could eventually strengthen the international role of the euro remains an open but highly relevant question.

Conclusion: Regulated Instruments of Power

Stablecoins are far more than lines of code on a blockchain. Those who issue them engage in regulated financial activity. Those who regulate them influence capital allocation and monetary reach. With MiCA in Europe and the GENIUS Act in the United States, the legal frameworks are now in place. The competition over the digital monetary infrastructure of the future has begun — and stablecoins sit at its center.