Stablecoins: Convergent Rules on the Surface, Divergent Regimes in Practice (CEPS)
This CEPS paper compares seven stablecoin regimes that look convergent on the surface—full or near‑full backing in liquid, segregated reserves, exclusion of algorithmic designs, and prohibition of yield—but in practice create divergent regimes through supervisory interpretation and reserve-allocation choices. It analyzes three main structural elements: treatment of foreign‑issued tokens, reserve composition, and whether to anchor stablecoins in existing law (for example, electronic money or payment instruments) or create sui generis categories. These choices reshape risk‑sharing and market structure by determining where the stablecoin float sits (commercial bank deposits, short‑dated sovereign debt, central bank balances, or trusts) and who captures seigniorage, as well as how far global fungibility survives under graduated market‑access models versus de facto exclusion. Key unresolved issues are the lack of a workable mutual‑recognition architecture, the under‑acknowledged redistributive nature of reserve rules, and the still‑implicit policy choice about whether stablecoins are payment money or investment instruments, given universal yield prohibitions. [CEPS]
