Stablecoins, tokenisation and the software shift: What the GENIUS Act means for financial services in the EU

Matthew Barnard, BBD Group Head: Financial Services

Why the next wave of regulation is reshaping digital money, and what it means for the technology behind it.

From regulation to reality

The digital-asset space just grew up. With the passing of the GENIUS Act in the United States, stablecoins (digital assets pegged to fiat currencies like the USD or EUR), once treated as fintech experiments, now sit inside a federal framework. It spells out who may issue them, how they’re backed, and how they plug into regulated finance. For global financial institutions, this is more than an American milestone; it’s a signal that tokenised money has moved from the innovation lab to the balance sheet.

The Act shifts the conversation from experimentation to implementation. In his view, the clarity now emerging in the U.S. sets a practical benchmark that banks, regulators and technology providers everywhere will inevitably calibrate against.

What the GENIUS Act actually changes

At its core, the Act creates a perimeter for payment stablecoins: permitted issuers, fully backed reserves, governance and disclosure obligations, and strict limitations on marketing. It also bars issuers from paying interest or yield to stablecoin holders, distinguishing these tokens from deposit products. Once the compliance perimeter is explicit, the technical perimeter can be engineered with purpose: reserve attestation pipelines, auditable mint–burn mechanics, jurisdiction-aware routing, and operational hooks for AML (anti-money-laundering), sanctions and lawful orders. In effect, stablecoins are no longer theoretical products; they’re regulated digital payment instruments that can be embedded safely into enterprise systems.

The U.S. Treasury Department has already launched formal rulemaking to implement the Act, focusing on anti-money-laundering controls, disclosures, and operational standards. Alongside GENIUS, further U.S. proposals such as the Digital Asset Market Clarity “CLARITY” Act aim to extend regulatory definition across the wider crypto market. 

Europe’s layered response

Europe has not mirrored the U.S. with a single statute; it has built a fabric. MiCA governs crypto-asset issuance and service providers (with phased implementation through 2025), PSD3 and the Payment Services Regulation modernise e-money and payments, DORA has been fully in effect since January 2025, and the DLT Pilot Regime (live since 2023) together with the ECB’s Pontes and Appia projects is exploring tokenised securities and central bank money settlement. This is a modular approach: Europe is weaving tokenisation into the existing financial system rather than declaring a new frontier. That choice fosters interoperability and supervision, but it also raises the bar for system readiness.

Across the region, early signals are already visible. A nine-bank consortium consisting of ING, UniCredit, KBC, Danske Bank, DekaBank, Banca Sella, SEB, CaixaBank and Raiffeisen Bank International has announced plans to issue a MiCA-compliant euro-denominated stablecoin, targeting a first launch in H2 2026. Meanwhile, the European Central Bank is piloting Pontes, a DLT bridge connecting distributed platforms to TARGET services, and Appia, a long-term solution integrating tokenised asset settlement directly into central-bank infrastructure, with pilots planned by Q3 2026. 

In parallel, Société Générale–Forge already operates EURCV, one of the first MiCA-aligned euro stablecoins, signalling that institutional-grade, regulated digital money is already live within the EU.

The regulatory scaffolding is therefore not theoretical; it’s becoming the operating environment for the next decade of European finance.

Convergence, divergence — and why timing matters

The U.S. framework legitimises tokenised money at scale; the EU’s fabric ensures depth of resilience. The strategic tension is currency and cadence. If USD-denominated rails scale faster, cross-border liquidity could tilt in their favour before euro-based alternatives mature. My advice is to be pragmatic: see it as a window, not a warning. Move quickly on euro-aligned tokenisation while ensuring platforms can safely interact with global stablecoin rails where policy allows.

The winners won’t be the loudest adopters. They’ll be the institutions that modernise quietly, engineer for resilience, and switch on new rails the moment policy and demand align.

The software shift: where the real work lives

This new era won’t be won in slide decks. It will be won in architecture diagrams, integration layers and runbooks. Four shifts will define success. 

1. Architecture and interoperability Core platforms must evolve from product-centric stacks to modular, API-driven architectures that run fiat and tokenised flows side by side. That means real-time mint–burn support, deterministic reconciliation between on-chain events and core ledgers, message adapters for SEPA/RTGS and compliance with the new EU Instant Payments Regulation, ensuring parity-priced, 24/7 euro transfers, and clean separation of custody models (self-custody vs hosted).For most banks, this also means confronting legacy integration challenges: reconciling real-time tokenised settlement with overnight batch accounting, ensuring consistent end-of-day positions across core and DLT ledgers, and linking smart-contract events to existing liquidity and collateral systems. Modernisation isn’t about replacing cores; it’s about decoupling them from everything that limits speed and visibility.
   

2. Compliance by design Compliance moves from process to software. Systems should validate permitted issuers at runtime, route by jurisdiction and licence, enforce disclosure-driven UI copy, and generate immutable audit trails by default. I’ll be blunt, bolt-on compliance will fail under production load. The only sustainable pattern is to encode rules into the workflow, the data model and the infrastructure itself.
   

3. Data and transparency Tokenised finance is data hungry. You’ll need pipelines that ingest issuer attestations, reserve breakdowns and stress metrics; models that surface risk and performance in real time; and governance that keeps those signals accurate, explainable and reportable. Observability is not a dashboard, it’s a discipline.
   

4. Resilience and operational readiness Under DORA (and common sense), resilience is measurable. Design for failure domains that cross clouds and chains, for incident drills that include smart-contract controls, and for lawful-order playbooks that are tested, timed and auditable. Tokenisation does not remove operational risk; it concentrates it unless the engineering is mature.

   
   

Evolving operating models

Technology alone won’t deliver readiness. Institutions will need new skills and governance models to manage tokenised infrastructure: engineers fluent in both core banking and blockchain, compliance teams who understand code audits as deeply as policy audits, and vendor-risk frameworks that extend beyond traditional service-level metrics to include smart-contract reliability and oracle dependencies. Leadership teams must treat this as a cross-disciplinary evolution. Architecture, operations, risk and legal can’t sit in separate rooms anymore. The moment value moves on-chain, everyone is in the same control loop.

What this means for European financial institutions

Put simply: we have entered the institutional phase of digital finance. Stablecoins, tokenised deposits and digital securities are converging into programmable, governable money and assets. The opportunity is not only new products; it’s cleaner settlement, faster liquidity cycles, composable services and better unit economics for payments and capital markets… if the stack is ready.

I would advise leadership teams to align architecture, risk and product now. Build the features you’ll need regardless of which token models dominate: permissioned asset registries, on-chain / off-chain reconciliation, jurisdictional routing, disclosure surfacing, freeze / unfreeze controls, and resilience runbooks that regulators can inspect and teams can execute.

Don’t chase headlines. Chase readiness. The moment policy clarifies or a partner ecosystem tips, you want to be the institution that can switch on safely in weeks, not rebuild for months.

Where BBD fits

BBD helps financial institutions modernise for this shift with architecture assessments that expose bottlenecks, integration frameworks for connectivity, data and cloud foundations that meet resilience and compliance expectations. 

Our role is straightforward: translate regulatory momentum into engineering momentum so you can adopt what matters, when it matters, without gambling on the hype cycle.

Closing thought

Tokenisation won’t reward the first proof of concept. It will reward the first production-grade system that stays fast, secure and compliant at scale. Build for that and the future has a way of arriving on your terms.