Three forms of tokenised money are routinely confused. Here is how Swiss and EU regulators draw the lines between deposit tokens, stablecoins, and synthetic CBDCs.
A deposit token (DT) is a digital representation of a sight deposit held at a licensed bank, issued natively on a blockchain. The holder owns the same legal claim as a traditional bank deposit: an unsecured liability of the issuing bank, covered by Swiss depositor protection (esisuisse, up to CHF 100,000 per client) and subject to the bank's capital, liquidity and resolution regime.
Under Swiss law, accepting deposits from the public on a professional basis requires a banking licence under the Banking Act (BankG) supervised by FINMA. The token is therefore not a new asset class — it is book money in a new technical form. The Swiss Bankers Association (SBA) white paper of February 2025 proposes a joint multi-bank Swiss Deposit Token (DT-CHF) on a public, permissioned settlement infrastructure, designed for programmable payments, DvP for tokenised assets and 24/7 interbank settlement.
Key consequences: deposit tokens may pay interest, are created when a bank extends credit (money creation by lending), and require interoperability and net settlement between issuing banks — typically anchored in central-bank money via SNB wholesale CBDC pilots (Project Helvetia).
A stablecoin is a crypto-asset that aims to maintain a stable value by reference to an official currency (fiat-backed) or other assets. The issuer is typically not a bank: it is an e-money institution, trust company or payment institution that holds segregated high-quality liquid assets (cash, short T-bills, overnight repo) equal to the tokens in circulation, and contractually redeems them at par.
Switzerland (FINMA). FINMA's Guidance 06/2024 classifies most payment stablecoins as deposits under the BankG (requiring either a banking licence or a default-guarantee structure with a Swiss bank under Art. 5(3)(c) BankV). Each token holder must be identified under the AML Act — there is no anonymous bearer issuance.
EU (MiCA). Fiat-backed stablecoins are E-Money Tokens (EMTs) requiring an EMI or credit-institution licence; multi-asset variants are Asset-Referenced Tokens (ART). Both must hold ≥1:1 reserves, honour par redemption, and may not pay interest to holders. United States. The GENIUS Act creates a federal payment stablecoin issuer (PSI) regime with strict reserve eligibility and a ban on yield to holders.
Unlike a deposit token, a stablecoin is not commercial-bank money: the reserve sits off the issuer's balance sheet in custody, and there is no fractional lending or money creation against it.
A synthetic CBDC (term coined by Adrian & Mancini-Griffoli, IMF, 2019) is a token issued by a regulated private intermediary whose entire liability to holders is backed, on a 1:1 basis and in real time, by deposits at the central bank. The central bank does not issue the token itself — it only provides the settlement asset — so this is sometimes described as a "narrow-bank stablecoin".
The holder's legal claim is on the private issuer, but credit and liquidity risk are effectively eliminated because the backing asset is central-bank money. This distinguishes an sCBDC from:
In Switzerland, no formal sCBDC regime exists today. Such a structure would require SNB sight-deposit account access for a non-bank issuer — currently restricted — combined with a FINMA licence. The closest live example internationally is Fnality, which operates an FMI-supervised Sterling payment system backed by an omnibus account at the Bank of England.
| Dimension | Deposit token | Stablecoin | Synthetic CBDC |
|---|---|---|---|
| Issuer | Licensed commercial bank | E-money / payment institution or trust company | Regulated intermediary (bank/PSP) |
| Legal nature of the claim | Commercial-bank deposit (book-money) recorded on a DLT | Claim on issuer redeemable 1:1 in fiat (e-money under MiCA) | Private liability fully backed by central-bank reserves |
| Backing | Bank balance sheet + capital + deposit insurance (esisuisse up to CHF 100k) | Segregated HQLA reserves (cash, T-bills <93d, repo) | 100% reserves at the central bank |
| Money type (BIS taxonomy) | Commercial-bank money (tokenised) | Private e-money | Indirect central-bank money |
| Swiss regulatory anchor | BankG (Banking Act) — deposit-taking under FINMA banking licence; SBA white paper Feb 2025 | FINMA Guidance 06/2024 — stablecoins as deposits or CIS; AMLA sub-relationships | Not formally defined; would sit under BankG + SNB account access (Project Helvetia) |
| Yield to holder | Possible (interest-bearing deposit) | Prohibited under MiCA EMT and US GENIUS Act | Typically none |
| Examples | SBA Swiss Deposit Token (DT-CHF) pilot, JPM Coin / Kinexys, SocGen EURCV | USDC, USDT, EURC, XCHF, CCHF | Fnality (GBP/EUR/USD), proposed BIS Project Agorá designs |
• Swiss Bankers Association, The Deposit Token — White Paper, 2023 / update 2025.
• FINMA Guidance 06/2024, Stablecoins: risks and challenges for issuers and guarantor banks.
• Adrian & Mancini-Griffoli, The Rise of Digital Money, IMF FinTech Note 19/01.
• BIS, The crypto ecosystem and financial stability and Project Agorá.
• Regulation (EU) 2023/1114 — MiCA (EMT & ART).