The Reserve Is the Product
For a stablecoin issuer, banking sits inside the product rather than underneath it. Every question a holder asks about the token is in substance a question about the reserve: which institutions hold it, in what form, and how quickly it turns into an outbound payment when someone redeems.
MiCA sets reserve, custody, and redemption obligations for asset-referenced tokens, and rules on investing the funds received and on redemption for e-money tokens. E-money token holders may redeem at par at any time; asset-referenced token holders are paid the market value of the referenced assets or receive those assets. Under both regimes the backing is kept apart from the issuer’s own assets and protected from its creditors: the reserve of assets for asset-referenced tokens, and the safeguarded funds for e-money tokens issued by an electronic money institution.[1] The practical consequence is that the issuer needs credit-institution relationships able to hold reserve deposits at scale, well beyond an operating account.
Institutions Test Four Things Before They Take Reserve Deposits
Reserve composition and where it will sit. Banks want to know the split between deposits and instruments, which institutions hold each leg, and the concentration limits. For asset-referenced tokens and significant e-money tokens issued by EMIs, the EBA’s draft technical standards, not yet adopted, would cap deposits with any one credit institution at 25%, 15%, or 5% of the reserve, depending on whether the bank is systemically important, large, or neither.[3]
Redemption mechanics. How a holder redeems, in what window, and what happens under stress when redemptions cluster.
Segregation and insolvency remoteness. Documented separation of reserve assets from the issuer’s own funds, with a structure that survives the issuer’s failure.
Attestation and reporting. Cadence, scope, and who signs it, and whether it covers what is owed to holders as well as the reserve assets. For an asset-referenced token, and for a significant e-money token issued by an EMI, MiCA also requires an independent audit of the reserve every six months.[1]
When an EMT Issuer Is an EMI
Under MiCA an e-money token may be issued by an authorised credit institution or an authorised electronic money institution. An EMT issuer that is an EMI safeguards the funds received for its tokens under the e-money regime, and MiCA Article 54 adds how those safeguarded funds must be held; a significant e-money token issued by an EMI follows MiCA’s reserve-of-assets rules instead of that safeguarding.
For a credit institution issuer, which that e-money safeguarding rule does not address, how Article 54 applies is a point to confirm with its competent authority.[2]
For an EMI issuing an e-money token that is not significant, the banking consequence is that at least 30% of the funds received for the tokens must always sit in separate accounts at credit institutions, with the rest invested in highly liquid low-risk assets in the same currency.[1] Institutions will ask how those funds are distinguished from any safeguarded float of ordinary e-money the issuer also issues, and applications that blur the two tend to stop there. The safeguarding side is covered in more depth on the EMI and payment institution banking page.
Reserve Deposits Are the Long Pole in the Stack
| Layer | Institution | Difficulty | Timeline |
|---|---|---|---|
| Reserve or token-fund deposits | Credit institutions, plural, with concentration limits | Hardest; scale and diversification both required | 3–9 months |
| Safeguarding (ordinary e-money float, if any) | Credit institution, or another method the e-money regime permits | Hard; to be distinguished from EMT funds, which MiCA Article 54 splits between credit-institution deposits and qualifying assets | 8–16 weeks |
| Operating account | Bank or EMI | Routine once authorised | 2–6 weeks |
| Redemption payout rail | Bank or EMI with instant capability | Moderate; speed is the constraint | 4–10 weeks |
Reserve placement cannot be compressed, because each institution applies its own concentration and onboarding limits and diversification means running several conversations at once. An in-principle decision from a first reserve-eligible institution comes sooner, at 4 to 12 weeks, and runs in parallel with the licence file; the three-to-nine-month figure is the full placement across a diversified set of institutions. Ranges are indicative across the partner network as of .
How Jagelski & Partners Helps
Issuer placement is sequenced around reserve capacity, because that is what constrains the size of the token rather than the ambition of the business plan. The assessment maps which credit institutions will take reserve deposits at the intended scale, what concentration limits they apply, and whether the combination reaches the target without a single point of failure.
The written assessment distinguishes the safeguarding arrangement from the reserve arrangement and identifies the required redemption capacity and attestation scope. An introduced independent specialist handles the payout-rail placement and any review of the issuer’s attestation.
Frequently Asked Questions
Because the reserve is the product. A token redeemable at par is backed by a pool of assets, and where that pool sits, who holds it, and how fast it converts to cash is the proposition itself. An issuer with a weak reserve banking arrangement has a product problem, not an infrastructure problem.
Under MiCA any investment of an asset-referenced token’s reserve must be in highly liquid low-risk instruments, and MiCA requires technical standards to set, for each official currency the token references, a minimum amount of that reserve held as credit-institution deposits. An electronic money institution issuing e-money tokens must hold a defined minimum proportion of the funds received as credit-institution deposits and invest the rest in such instruments, so the relationship is a regulatory requirement rather than an operational preference.
No. MiCA requires the reserve of an asset-referenced token to be segregated, insolvency-remote, and held in custody only by credit institutions, eligible investment firms for financial instruments, or authorised custody CASPs for crypto-assets, and for e-money tokens a defined minimum proportion of the funds must sit as deposits at credit institutions. An EMI authorisation alone does not permit deposit-taking or custody of asset-referenced token reserve assets.
Issuers therefore need credit-institution relationships for the deposit leg and eligible custodians for any other reserve assets, and can use EMI relationships for operations.
Concentration risk. A reserve held at a single institution is a single point of failure for redemption, and for asset-referenced tokens and significant e-money tokens issued by EMIs, MiCA requires the issuer to avoid concentrations of custodians and of reserve assets. Each institution also applies its own concentration and onboarding limits, so reaching scale usually requires several relationships regardless of preference. That is why reserve banking runs three to nine months: diversification means running several conversations in parallel rather than one after another.
For an EMI issuing e-money tokens that are not significant, they are layered, not separate: the funds received for the tokens are safeguarded under the e-money regime, and MiCA Article 54 sets how those funds are held. A reserve of assets under MiCA applies to asset-referenced tokens and, instead of e-money safeguarding, to significant e-money tokens issued by an EMI. Institutions ask how the token funds are distinguished from any other e-money float.
Applications that blur these layers tend to stop there, because it suggests the issuer has not separated its funds operationally either.
By asking what happens under stress. How a holder redeems, in what window, and what the arrangement does when redemptions cluster. The reserve has to convert to outbound payments faster than the redemption promise, and that is a banking question rather than a treasury one.
An issuer promising instant redemption on a rail that settles next day has a mismatch an institution will find before its customers do.
Only if it covers liabilities as well as assets. An attestation proving reserve assets exist without proving what is owed against them does not establish full backing, and institutions know the difference.
Presenting an assets-only attestation as complete damages credibility with exactly the institutions the issuer needs. Cadence, scope, and signatory are all asked about.
Reserve or token-fund deposits are the long pole at three to nine months and cannot be compressed. Safeguarding runs 8 to 16 weeks, the redemption payout rail 4 to 10 weeks, and operating accounts 2 to 6 weeks.
All of them should run in parallel with the authorisation rather than after it, because reserve capacity constrains the size of the token regardless of what the business plan says.
Yes. E-money tokens referencing a single official currency and asset-referenced tokens referencing a basket or other assets carry different backing composition and reporting obligations under MiCA, and the banking arrangement follows the composition.
An asset-referenced token with a non-deposit component needs custody and valuation arrangements under MiCA’s reserve rules, which apply to a single-currency EMT only where it is issued by an electronic money institution and is significant, or where that institution’s competent authority requires them.
Operating and payout costs sit in the normal fintech range, at roughly 100 to 500 euro a month for an EMI relationship. The material cost is not fees but reserve economics: concentration limits, minimum balances, and the yield foregone on the deposit leg.
Ranges are indicative across the partner network as of June 2026.
No. Jagelski & Partners is paid by the institution that takes the business, through a referral or revenue-share arrangement, not by a fee billed to the client. The pricing is the institutional rate, with no markup and no onboarding fee.
Ready to Size the Reserve Against Real Bank Capacity?
Book an assessment. We map which credit institutions will take reserve deposits at the intended scale, what concentration limits they apply, and whether the combination reaches the target without a single point of failure, then an introduced specialist places safeguarding and the redemption rail as separate problems. No markup on institutional pricing. No onboarding fee.
References
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- European Union, Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA), Titles III–IV (Articles 36–39: asset-referenced token reserve, custody and redemption at the market value of the referenced assets or by delivery of those assets, including the six-monthly independent audit of the reserve under Article 36(9) and the avoidance of custodian and reserve-asset concentrations under Article 37(1); Article 49: e-money token redemption at par; Article 54: investment of funds received in exchange for e-money tokens, with at least 30% always deposited in separate accounts in credit institutions under Article 54(a); Article 58: reserve rules for significant e-money tokens issued by electronic money institutions); applicable from , eur-lex.europa.eu, accessed .
- European Union, Directive 2009/110/EC on electronic money institutions (EMD2), Article 7: safeguarding of funds received in exchange for electronic money, eur-lex.europa.eu, accessed .
- European Banking Authority, Opinion on the European Commission’s amendments relating to the final draft Regulatory Technical Standards to further specify the liquidity requirements of the reserve of assets under Article 36(4) of Regulation (EU) 2023/1114 (EBA/Op/2025/13), , Annex Articles 1, 4 and 6 (draft: at least 30% of the reserve in credit-institution deposits, 60% for significant tokens; deposits with a single credit institution capped at 25%, 15%, or 5% of the reserve and at 1.5% of that institution’s total assets), eba.europa.eu; status “final draft adopted by the EBA and submitted to the European Commission”, eba.europa.eu, both accessed .