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Response to the 2025 BIS Report: Stablecoins, CBDCs and the Search for “Sound” Digital Money
26. Juni 2025 | Medienmitteilung

Response to the 2025 BIS Report: Stablecoins, CBDCs and the Search for “Sound” Digital Money

The new BIS report, published on 24 June 2025 repeats a familiar verdict: stablecoins fail the tests of singleness, elasticity and integrity. We agree that weakly regulated coins deserve scrutiny, but we do not accept that every well-structured, fully backed stablecoin must share the same fate. Progress lies in calibrating tools to purposes, not in blocking innovation until perfection arrives.

1  Singleness – one euro should equal one euro

MiCAR already requires issuers to hold reserves in central-bank money or high-quality liquid assets and to grant legally enforceable redemption at par. This satisfies the practical definition of singleness for day-to-day settlement.

It is also worth noting that “public money” is not identical across jurisdictions. The value of central-bank liabilities ultimately depends on the credit and institutional strength of the sovereign. History—from Argentina to Zimbabwe—shows that even state money can fragment. Regulation therefore matters more than the issuer’s label. A MiCAR-compliant euro stablecoin, transparently collateralised and supervised, can deliver comparable or better certainty than many national fiat currencies.

2  Elasticity – how much liquidity is really required?

Stablecoins are fully pre-funded and cannot expand balance-sheet length in a crisis. That is by design: they aim to be settlement instruments, not macro-stabilisation tools.

Liquidity management: Issuers can hold a portion of reserves in overnight central-bank deposits or very short-dated government bills. Same-day redemption is thus feasible without maturity mismatch.

Fit-for-purpose scope: In securities settlement, collateralised lending or automated payments, users value immediate finality and on-chain programmability more than aggregate money-supply flexibility.

Complementarity: If the public sector believes additional elasticity is essential, the answer is a wholesale-ready CBDC, not a prohibition on private innovation. CBDC would cover high-powered liquidity needs, while regulated stablecoins handle routine on-chain cash legs.

3  Integrity – compliance can be built in

MiCAR brings stablecoin issuers and wallet providers fully under EU AML/CFT rules. On-chain records allow near-real-time forensic analysis, and smart contracts can enforce transfer limits or whitelist requirements. Properly regulated stablecoins therefore raise the bar for transparency rather than lower it.

Conclusion – “Good enough” can be exactly right

Digital finance will need a spectrum of instruments. A CBDC may become the digital savings account of choice, backed directly by the Eurosystem. MiCAR-compliant stablecoins can serve as the liquid, programmable cash leg for risk-bearing market activity. Each tool solves a different problem; neither must be flawless for both to add value.

The BIS is right to highlight weaknesses in unregulated models. Yet simply restating those weaknesses without acknowledging the regulatory progress already made keeps the financial sector in limbo. If the official community believes only sovereign money can meet every theoretical test, then the logical next step is to accelerate the digital euro. Until that exists, well-designed stablecoins remain the most practical bridge between today’s markets and tomorrow’s tokenised economy.