Stablecoins and tokenisation: from the digital franc to on-chain securities
What a stablecoin is, how Switzerland, the EU and the United States regulate it, what it means to tokenise a real asset and which risks to consider.
Stablecoins are the part of crypto that interests companies and banks most, because they promise fast payments without the swings in value typical of bitcoin. Tokenisation, that is representing a right over a real asset with a token, is the next step. This article explains both, with the regulatory picture in Switzerland, the European Union and the United States, based on official sources.
What a stablecoin is
The Federal Council describes stablecoins as cryptocurrencies pegged to an asset, usually the US dollar and sometimes the Swiss franc, with a value-stabilising mechanism. The idea is that 1 unit of the digital currency corresponds to 1 unit of the reference currency. UBS's press release of 8 September 2026 describes the CHFD project this way: a stablecoin designed to maintain a 1:1 peg to the Swiss franc.
The rules in Switzerland
Today Switzerland has no dedicated law. FINMA applies the existing rules: in its supervisory guidance 06/2024 it explains that stablecoin issuers may fall under the Banking Act or the Collective Investment Schemes Act, and that many issuers use a bank's default guarantee to avoid a banking licence. It sets minimum requirements for this guarantee, including an individual claim for each customer against the bank and cover at least equal to public deposits. In addition, according to PwC's summary, the identity of all holders must be verified and anonymous transfers are prohibited. On 22 October 2025 the Federal Council opened a consultation, closed on 6 February 2026, on two new licences: payment instrument institutions, which could issue stablecoins and would have to segregate client funds, and crypto institutions. This is a draft, not a rule in force.
The rules in the European Union and the United States
In the EU the MiCA rules for e-money tokens and asset-referenced tokens have applied since 30 June 2024. According to the European Banking Authority, as of 1 September 2026, 39 e-money tokens had been issued and no asset-referenced token had been authorised. ESMA recalls that anyone who wants to offer a stablecoin in the Union must obtain authorisation from the national authority, and proposes to ban authorised providers from offering services on non-compliant stablecoins. In the United States the GENIUS Act takes effect on 18 January 2027: after that date it will generally be unlawful to issue payment stablecoins without a licence or approval.
What tokenisation is
Tokenising means recording on a blockchain a right relating to an existing asset, for example a security, a fund unit or a receivable. In English this is called real-world assets, abbreviated RWA. It does not change the nature of the asset: it changes how it is recorded and transferred. ESMA argues that Europe should adopt clearer rules for tokenising existing securities and for on-chain settlement, and points to uncertainty over issuance, legal title, custody, settlement finality and cross-border enforceability as obstacles. In the United States too the subject has entered the rules: the SEC's custody proposal adds questions on tokenised fund shares to the disclosure forms.
The risks to know
A stablecoin is not a bank account. The sources point to a few areas of attention:
- the issuer: guarantee and redemption depend on who issues and how the funds are held; the EBA notes that the reserve rules, in particular the minimum amount to be held in deposits, should be reviewed;
- identity verification: in Switzerland, according to FINMA in PwC's summary, anonymous transfers of stablecoins are not permitted, which limits free circulation;
- freezing: issuers can block tokens linked to a crime, as in the case of the $10 million of USDT frozen by Tether in October 2026 according to CoinDesk;
- the experimental stage: the digital franc sandbox, with nine participants among Swiss banks and companies, is a pilot initiative until the end of 2026 and does not anticipate a launch decision.
What it means for an SME
Today, for most Swiss SMEs, stablecoins are a subject to watch rather than adopt. If you are considering accepting them or using them to pay foreign suppliers, it is worth checking who the issuer is, which regime governs it, how redemption works and how it is accounted for. These are questions for the tax adviser and the bank, not for the website. ElaraTeq can help, if anything, to tell customers clearly what you accept and how.
Sources
- Federal Council, press release of 22.10.2025 on the stablecoin and crypto consultation: https://www.bag.admin.ch/en/newnsb/x4TMWQ1SWofNoFx7XyHhY
- FINMA, Guidance 06/2024 on stablecoins, 26.07.2024: https://www.finma.ch/en/~/media/finma/dokumente/dokumentencenter/myfinma/4dokumentation/finma-aufsichtsmitteilungen/20240726-finma-aufsichtsmitteilung-06-2024.pdf
- PwC Switzerland, FINMA Stablecoin guidance: https://www.pwc.ch/en/insights/regulation/finma-stablecoin-guidance.html
- EBA, The EBA identifies priorities for the review of MiCA: https://www.eba.europa.eu/publications-and-media/press-releases/eba-identifies-priorities-review-mica
- ESMA, response to the consultation on the MiCA review, 30.09.2026: https://www.esma.europa.eu/sites/default/files/2026-09/ESMA75-113276571-1721_Response_to_the_EC_consultation_MiCA_regulation_review.pdf
- Paul Hastings, regulatory summary of 05.10.2026 (GENIUS Act, SEC): https://www.paulhastings.com/insights/crypto-policy-tracker/sec-proposes-crypto-custody-framework-treasury-issues-interim-final-rule-on-state-stablecoin-certifications-cftc-submits-two-rules-to-the-white-house
- UBS, CHF stablecoin sandbox enters test phase, 08.09.2026: https://www.ubs.com/global/en/media/display-page-ndp/en-20260908-stablecoin-sandbox.html
Information, not advice.