By CoinGecko's category totals on 13 September 2026, stablecoins pegged to the US dollar were worth about $288.5 billion, out of roughly $291.3 billion for its stablecoin category as a whole. Euro stablecoins came to about $774 million and sterling stablecoins to about $27 million. The two largest Swiss franc tokens it listed, AllUnity CHF and Frankencoin, were worth about $47.7 million and $42.9 million. Data providers count differently, and rwa.xyz put the whole stablecoin market at $304.58 billion on the same day, but on either count the three European currencies together make up well under 1% of it.

The imbalance is not new. In a post on The ECB Blog dated 28 July 2025, "From hype to hazard: what stablecoins mean for Europe", Jürgen Schaaf wrote that dollar stablecoins accounted for "some 99%" of total stablecoin market capitalisation and that euro-denominated stablecoins had a market capitalisation of "less than €350 million". It is a blog post, not a policy decision: the ECB states that blog entries give the author's views and do not necessarily represent those of the ECB and the Eurosystem.

Why European policymakers care about a market this small

Schaaf's post sets out the case. Visa and Mastercard were already integrating stablecoins into their offerings, and large US merchants were exploring them. The Bank for International Settlements, in its Annual Economic Report 2025, had warned that stablecoins could undermine monetary sovereignty and that many had seen "substantial deviations from par". The post also identified a channel that bites harder in Europe. Some platforms pay interest on stablecoin holdings; if interest-bearing stablecoins became common among businesses, they could draw deposits away from banks, which play a central role in Europe's financial system and rely on deposits as their main source of refinancing. Wide use of dollar stablecoins in the euro area, the post argued, could also weaken the ECB's control over monetary conditions.

The euro: MiCA's e-money token regime

Who may issue, and on what terms

Under Regulation (EU) 2023/1114 (MiCA), a person may offer an e-money token to the public or seek its admission to trading in the EU only if that person is the issuer, authorised as a credit institution or an electronic money institution, or has the issuer's written consent (Article 48(1)). Holders have a claim against the issuer. Tokens must be issued at par on receipt of funds and redeemed on request, at any time and at par, in funds other than electronic money, and redemption may not carry a fee (Article 49). Article 50 bars issuers, and crypto-asset service providers providing services related to e-money tokens, from granting interest; any remuneration or other benefit linked to how long a holder keeps the token counts as interest, including discounts with an equivalent effect. Article 54 requires at least 30% of the funds received to be deposited in separate accounts at credit institutions, with the rest invested in secure, low-risk, highly liquid instruments denominated in the currency the token references. Titles III and IV of MiCA, covering asset-referenced and e-money tokens, have applied since 30 June 2024.

Significant tokens, and the multi-issuance question

The European Banking Authority classifies an e-money token as significant when at least three of the criteria in Article 43(1) are met (Article 56(1)): more than 10 million holders; a value, market capitalisation or reserve above €5 billion; an average of more than 2.5 million transactions and €500 million in value a day; an issuer designated as a gatekeeper under the EU's Digital Markets Act; significance on an international scale, including for payments and remittances; interconnectedness with the financial system; and an issuer that also issues another asset-referenced or e-money token and provides at least one crypto-asset service. Supervision of the issuer then generally passes to the EBA. An electronic money institution issuing a significant token becomes subject to reserve, own-funds and liquidity requirements drawn from the asset-referenced token rules, and its reserve must be independently audited every six months (Article 58(1)).

MiCA's text addresses multi-issuance in one place: where several issuers issue the same token, the significance criteria are assessed on their aggregated data (Articles 43(3) and 56(2)). The Regulation as adopted does not expressly say how a token issued interchangeably by an EU-authorised issuer and an issuer outside the EU should be treated, including which entity's reserve answers for units redeemed in the EU. That is the multi-issuance question the text leaves open.

A bank consortium's euro token, not yet authorised

Banks are building their own. Qivalis, an Amsterdam company founded in September 2025, announced on 20 May 2026 that its consortium had grown to 37 banks, among them BNP Paribas, BBVA, ING, UniCredit and Danske Bank, and that it was pursuing authorisation from De Nederlandsche Bank as an electronic money institution ahead of a launch it anticipated in the second half of 2026. The disclosure on its website, last updated on 28 August 2026, says Qivalis B.V. has applied for that authorisation, is not yet authorised and does not currently issue electronic money.

Sterling: one rulebook final, the other still a draft

The UK splits the work. The FCA will regulate the issuance of UK stablecoins, and issuers that HM Treasury recognises as systemic under the Banking Act 2009 will be regulated jointly by the FCA and the Bank of England. As of 13 September 2026 neither set of rules applies to anyone yet, for different reasons, which is why separating a published rule from one in force matters so much here.

The FCA consulted in CP25/14, open from 28 May to 31 July 2025, and published its final rules in Policy Statement PS26/10 on 30 June 2026. The FCA says UK-issued qualifying stablecoins will be required to be fully backed and redeemable at par. Issuers must place a payment order for a redemption by the end of the next business day (T+1); under the final rules that clock starts when the issuer receives the tokens being redeemed, so anti-money-laundering checks come before it. The instruments come into force on 25 October 2027, the date from which, the FCA says, the full scope of regulated cryptoasset activities begins. The rules are made, but not yet applying.

The Bank of England published its policy statement on sterling-denominated systemic stablecoins on 22 June 2026, with a consultation on a draft Code of Practice, which will contain the rules. Feedback is due by 22 September 2026, and the Bank intends to finalise the Code by the end of 2026. Its positions: in steady state, at most 70% of backing assets in UK government debt with up to six months to maturity and 30% in unremunerated Bank of England deposits; a temporary issuance guardrail of £40 billion for each systemic stablecoin, in place of the holding limits it consulted on in 2025; and redemption by the end of the day, which it defines as within 24 hours on a rolling basis once the issuer has the request, has completed anti-money-laundering checks and has received the tokens. The FCA and the Bank have also published a joint approach for firms moving from FCA-only regulation to joint regulation, which includes a further consultation on transitional arrangements.

Swiss franc: bank guarantees, a draft licence and a design with no issuer

Switzerland currently regulates stablecoins through existing financial market law, as FINMA applies it. FINMA Guidance 06/2024, "Stablecoins: risks and challenges for issuers of stablecoins and banks providing guarantees", published on 26 July 2024, says stablecoin holders generally have a payment claim against the issuer, usually categorised as a deposit under banking law or, depending on whose account and risk the underlying assets are managed for, a collective investment scheme. Accepting public deposits on a professional basis generally requires a banking licence, but funds whose repayment is guaranteed by a bank are not treated as deposits from the public (Article 5(3)(f) of the Banking Ordinance). FINMA notes that various Swiss stablecoin issuers use such default guarantees and so need only be affiliated to a self-regulatory organisation.

FINMA sets minimum conditions for that guarantee. Each customer must have their own claim against the guaranteeing Swiss bank if the issuer goes bankrupt, and must be informed of the guarantee; the guarantee must cover at least all public deposits, including any interest; covered deposits must never exceed its upper limit; its terms must not prevent a simple, rapid call on it; and the bank keeps the defences the law allows. Even then, FINMA says, the protection is not comparable to that of a banking licence, and holders do not benefit from depositor protection under Article 37a of the Banking Act. FINMA also cites a Federal Council report on the Banking Act concluding that the default-guarantee exception was being used to structure business models outside the licensing framework and that the exceptions should be reviewed.

A reform is at consultation stage, not law. On 22 October 2025 the Federal Council opened a consultation on amending the Financial Institutions Act, according to a fact sheet from the State Secretariat for International Finance (SIF). It proposes two new licences. Payment instrument institutions would replace the fintech licence, with the CHF 100 million limit on client deposits removed and client funds segregated if an institution fails; only they could issue "stable crypto-based payment instruments", tokens issued in Switzerland that aim to hold a stable value against a single state currency and carry a right to reimbursement, and issuers would have to publish a white paper. Crypto-institutions would be licensed to provide services in other cryptoassets, a category that includes stablecoins issued abroad. The consultation ran until 6 February 2026, and the Federal Council said it would submit a dispatch to parliament in the second half of 2026 at the earliest. The SIF's pages, checked on 13 September 2026, record the consultation but no dispatch.

Frankencoin sits apart from both models. Its website says its value "does not depend on an issuer that guarantees its value"; it is backed instead by on-chain collateral that can be liquidated. Its documentation describes an over-collateralised system with no hard peg to the franc, relying on economic incentives to push the price towards parity, and a separate governance token whose holders carry the residual risk of liquidations. On 13 September 2026 the site displayed about 34.9 million ZCHF in circulation against collateral it valued at about 67.9 million ZCHF. It still engages with European rules: finews.ch reported on 30 June 2026 that the Frankencoin Association had published a MiCA white paper for the token in the EU register, which the Association said gave regulated EU exchanges a basis to offer it.

On the Paris 2026 programme

The three currencies were the subject of a panel at Proof of Talk Paris 2026, at the Louvre Palace. "Beyond USD: The Future of Euro, Sterling and Swiss Franc Stablecoins" ran on the Hecto Main Stage on 3 June 2026, 14:00–14:40, with Arnaud Caudoux, Elliot Hentov, Sasha Mills, Executive Director for Financial Market Infrastructure at the Bank of England, and Johannes Kern, managing director of the Frankencoin Association. Lisa Cameron moderated. Earlier that day, 10:30–11:30 on the X Ventures Masterclass Stage, Tero Reuna was listed for "Bringing the Global Dollar Network to Europe: How Regulated, Network-Driven Stablecoins Are Unlocking Growth". Both sessions remain on the archived agenda.

What to compare before using one

Five points separate these instruments more than their currency does, and they overlap with the questions that divide stablecoins, tokenised deposits and money market funds. None of this is investment, legal or tax advice.

  • Legal claim and redemption. A MiCA e-money token gives the holder a claim against an authorised issuer, redeemable at par at any time and without a fee. Under the FCA's rules, from 25 October 2027, a UK-issued stablecoin carries a right to redeem at par, with payment by T+1. A Swiss token issued under a default guarantee leaves the holder with a claim on the issuer and, if the issuer goes bankrupt, on the guaranteeing bank, without statutory depositor protection. Frankencoin has no issuer promising redemption; its peg rests on collateral and incentives.
  • Reserve and backing. MiCA sets a floor of 30% of funds in separate accounts at credit institutions. The Bank of England's draft systemic regime caps UK government debt at 70% in steady state and puts the rest in unremunerated deposits at the Bank, the same central bank money that tokenised settlement projects are built around. FINMA's guidance on the default-guarantee route sets conditions for the guarantee, not a composition rule for backing assets. Frankencoin relies on over-collateralisation.
  • Issuer type and supervision. Under MiCA, a credit institution or electronic money institution, with supervision of significant tokens generally passing to the EBA. In the UK, an FCA-authorised issuer, jointly regulated with the Bank of England once HM Treasury recognises it as systemic. In Switzerland, a bank, or an issuer relying on a bank's default guarantee, the route FINMA says various issuers use. For Frankencoin, a protocol with no issuer.
  • Liquidity against the dollar. On CoinGecko's September 2026 totals, dollar stablecoins were worth more than 300 times all euro stablecoins combined. Order-book depth, spreads and the number of venues quoting a given token are the practical measures of that gap.
  • Access to ramps. Whether an institution can mint and redeem directly with an issuer or only through intermediaries, and whether its existing exchanges, brokers and custodians support the specific token, decides how usable it is. Qivalis, for one, says its token will be distributed through partners.