José Luis Escrivá, governor of the Bank of Spain, told a forum on September 15 that tokenised bank deposits represent "una alternativa clara a las criptomonedas" — a clear alternative to cryptocurrencies. The remark lands as Spanish and European authorities push forward two parallel projects: bank-issued tokenised deposits and the digital euro, both pitched as safer substitutes for private crypto assets.

Five Spanish lenders — Abanca, Cecabank, Ibercaja, Kutxabank and Unicaja — completed a tokenised deposits test in July, conducted in a closed environment with no commercial launch date set. Escrivá said any new design must keep deposits "asegurados en cualquier nuevo diseño" and stressed the role of central banks "detrás del asentamiento final" — behind the final settlement — "no solamente por temas de garantía sino también de poder dar liquidez al sistema cuando se produzcan fricciones."

On the digital euro, Escrivá confirmed the project will carry "límites individuales estrictos" on how much citizens can hold in their wallets. Discussions have centred on a per-person cap of between EUR 3,000 and 4,000, with companies barred from holding digital euros for more than 24 hours. The ECB's own simulations suggest that at a EUR 3,000 threshold, nearly EUR 700 billion could migrate out of bank deposits into digital euro wallets. The European Parliament's Economic Affairs Committee has left the exact figure to later technical rules, to be reviewed every two years.

Lessons from bank runs

The caution reflects recent history. An ECB working paper found that after the 2023 collapse of US regional lenders and Credit Suisse, bank runs accelerated due to online banking, faster payments and social media. The Swiss National Bank has acknowledged that the scale and pace of Credit Suisse's deposit outflows were unprecedented. An ECB macroprudential bulletin published in April warned that programmability in digital money could enable automatic triggers, increasing herd behaviour or the risk of programmed bank runs. The Financial Stability Board noted in 2024 that the stability of tokenised instruments could weaken if deposit insurance coverage is unclear.

US research backs the banks' preference for tokenisation over stablecoins. The Federal Reserve Bank of New York stated in 2022 that tokenised deposits continue financing credit, unlike stablecoins, and Dallas Fed economists confirmed in July that tokenisation preserves liquidity transformation, with banks still using deposits to fund long-term assets. The Dallas Fed estimated in August that a 10% shortening of deposit average life would cut the banking system's term transformation capacity by roughly USD 580 billion.

MiCA under pressure

Europe's stablecoin rules are also shifting. MiCA requires issuers to hold at least 30% of reserves in bank deposits, rising to 60% for very significant issuers — a rule Tether cited when it declined to seek an EU licence in 2024, warning it created systemic risks; USDT subsequently exited regulated EU platforms. This week the European System of Central Banks asked to eliminate that reserve rule, arguing it could strain bank liquidity during rapid redemptions. Meanwhile 37 banks from 15 countries are building their own euro stablecoin through the Qivalis consortium.

Christine Lagarde has described the interbank settlement layer Pontes as "un euro digital puesto a disposición de los bancos" — a digital euro made available to banks. Banks have had uncapped access to Pontes since September 21. A retail digital euro for citizens, with the debated caps, is not expected before 2029.

Cash limits and reporting rules

The debate unfolds alongside tightening cash and reporting rules. An EU anti-money laundering regulation will cap cash payments to merchants or professionals at EUR 10,000 from July 2027; Spain has applied a EUR 1,000 limit since 2021. Eurostat data show deposits make up a third of households' financial assets. The bloc's DAC8 directive, obliging crypto service providers to report client data to tax authorities, has been in force since January 1, 2026. France's Conseil d'État rejected a bid to suspend the decree applying DAC8 on September 14, calling the risk "muy baja" — very low — even as the French tax administration disclosed unauthorised access and data theft affecting its systems between June and August.