Money or Credit? MiCA's Stablecoin Hybrid and the Direction of the 2026 Review

Allan Pedersen

No 2, Philosophers Mint Working Papers from Philosophers Mint

Abstract: Are stablecoins a new kind of money, or a new kind of bank? Europe's Markets in Crypto-Assets Regulation (MiCA) has never quite decided. It treats a fiat-backed stablecoin (an e-money token) as a digital wrapper around existing money, yet loads the issuer with much of a bank's prudential machinery. The result is coherent in one case and unstable in another, depending on who issues it. A bank-issued token sits inside the public safety net, and the arrangement holds. A non-bank issuer faces the same bank-grade rules but no safety net: an instrument that promises to be worth one euro, invests in assets that can lose value, and has nothing to fall back on in a panic. Those three features cannot all hold at once. Reading the 2026 review consultation as a live document, the note finds three EU institutions pulling this corner three ways, and argues the review should choose one coherent design, not fine-tune an incoherent middle.

Keywords: stablecoins; e-money tokens; MiCA; regulatory perimeter; private money; lender of last resort; monetary sovereignty; digital euro (search for similar items in EconPapers)
JEL-codes: E42 E58 G21 G28 (search for similar items in EconPapers)
Date: 2026-06
Note: Also available as SSRN 10.2139/ssrn.6917858; a SUERF Policy Note version is forthcoming.
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Persistent link: https://EconPapers.repec.org/RePEc:pmt:wpaper:2

DOI: 10.2139/ssrn.6917858

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