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 both asset-referenced tokens and e-money tokens. E-money token holders may redeem at par at any time; asset-referenced token holders redeem at the market value of the referenced assets. Under both regimes the reserve assets are segregated from the issuer’s own assets and held so they are insolvency-remote.[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. A reserve concentrated at one bank is a single point of failure for redemption, and supervisors read it the same way.
Redemption mechanics. How a holder redeems, in what window, and what happens under stress when redemptions cluster. This is where an issuer’s banking arrangement is actually tested, because the reserve has to convert to outbound payments faster than the redemption promise.
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. An attestation covering assets without covering liabilities does not establish that the token is fully backed, and presenting it as though it does damages credibility with exactly the institutions the issuer needs.
An EMT Issuer Is Usually Also an EMI
Under MiCA an e-money token may be issued by an authorised credit institution or an authorised electronic money institution. That means most EMT issuers carry an EMI authorisation and inherit its safeguarding regime alongside the MiCA reserve regime, which is two overlapping sets of obligations rather than one.
The banking consequence is that the issuer needs both a safeguarding arrangement for e-money float and a reserve arrangement for token backing, and institutions will ask how the two are kept distinct. Firms that conflate them in the application find the conversation stops 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 deposits | Credit institutions, plural, with concentration limits | Hardest; scale and diversification both required | 3–9 months |
| Safeguarding (e-money float) | Credit institution | Hard; distinct from the reserve | 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. Pre-qualification with a first reserve-eligible institution is quicker, 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 same assessment separates the safeguarding arrangement from the reserve arrangement explicitly, places the redemption payout rail against the redemption promise, and checks the attestation scope before it is published rather than after an institution has read it.
Frequently Asked Questions
Because the reserve is the product. A token redeemable at par is a claim on 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 the reserve must be invested in highly liquid low-risk instruments and, for e-money tokens, a defined minimum proportion held as credit-institution deposits, so the relationship is a regulatory requirement rather than an operational preference.
No for the deposit leg. MiCA requires reserve assets to be held so they are segregated and insolvency-remote, and for e-money tokens a defined minimum proportion must sit as deposits at credit institutions. An EMI safeguards rather than takes deposits and cannot fill that role.
Most issuers therefore run credit-institution relationships for the reserve alongside EMI relationships for operations.
Concentration risk. A reserve held at a single institution is a single point of failure for redemption, and supervisors read it exactly that way. 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.
They are separate obligations that most EMT issuers carry simultaneously. Safeguarding protects e-money float under the EMI regime; the reserve backs the token under MiCA. Institutions ask how the two are kept distinct.
Applications that conflate them tend to stop there, because conflating them suggests the issuer has not separated the two pools 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 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 reserve 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 that a single-currency EMT does not.
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 place 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; Article 49: e-money token redemption at par; Article 54: reserve deposits with credit institutions); applicable from , eur-lex.europa.eu, accessed .