(10) Stablecoins in the EU – by Noelle Acheson

I was watching a recent video of a conversation between two of the industry observers that I always pay attention to: Noelle Acheson and Marieke Flament. I subscribe to both of their substacks and always take their comments very seriously. Apart from very jealous of their ability to wear such a depth of knowledge so lightly, I found myself engrossed in their discussion about EU stablecoin evolution and, more specifically, what a modern “money stack” should look like.

Marieke made the point that (and I am paraphrasing here) wholesale central bank digital currency (CBDC)  is a basic and uncontroversial platform for the next generation of financial services.

The 2026 Global Payments Report | McKinsey

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The emerging control layer and protocol standards

As basic authorization and transaction clearing become increasingly commoditized, five product capabilities capture emerging infrastructure value:

agent credentials—cryptographic identities that bind software agents to human or corporate principals, defining clear authority boundaries and enabling instant revocation
mandate and consent engines—standardized protocols that specify what an agent is permitted to execute, including spending caps, approved counterparties, and active expiration windows
runtime policy guardrails—granular spending rules enforced at runtime, such as velocity throttles and category restrictions
agent wallets—programmatic liquidity containers that enable autonomous agents to hold operating balances and execute micropayments within defined parameters.
transaction dispute frameworks—recourse mechanisms and clear liability allocations when an agent executes a transaction that technically complies with its mandate yet conflicts with user intent
These infrastructure components generate recurring per-mandate fees, API call pricing, and risk underwriting premiums rather than transaction volume basis points.

Market participants are establishing complementary protocols in different layers of the transaction stack. Card network initiatives such as Visa’s Trusted Agent Protocol and Mastercard Agent Pay focus on machine identity and network dispute rules. At the same time, application standards such as Google’s Agent Payment Protocol and the Stripe and OpenAI Agentic Commerce Protocol govern runtime checkout interactions.

From: The 2026 Global Payments Report | McKinsey.

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Banks: Own trust & identity

Remember back in section 2, page 14 when McKinsey recommended banks own the Identity layer? Section 3, page 25 is the only other time they mention it:

“Issue verifiable machine credentials, manage delegated authorization and consent mechanisms, and actively shape industry standards before protocols become fixed.”
That may work in countries where the top 3-5 banks have ~90% share. They can coordinate to offer a shared credential based on their internal KYC. But in the US, the top 10 banks have <60% share with a long tail of thousands of banks. The big banks tried to create an identity bureau at EWS in 2015-2019, but never launched. I never knew why, but liability may have been a contributing factor.

For the US, this recommendation seems gratuitous. No bank has enough consumer DDA share to do this on their own and doing it as an industry already failed. Bringing in the long tail might take forever (e.g., Fednow, Zelle). The biggest eCommerce acquirers and the card networks might get there sooner. So might Apple, at least for iPhone users.

From: Assessing the McKinsey Global Payments Report.

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Attorney General Bonta’s Sponsored Bill to Return Stolen Digital Assets to Victims Signed into Law | State of California – Department of Justice – Office of the Attorney General

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This gives law enforcement a mechanism to return stolen cryptocurrency even when it has been commingled with other funds, as is common in multi-victim fraud schemes and organized money laundering investigations in California

From: Attorney General Bonta’s Sponsored Bill to Return Stolen Digital Assets to Victims Signed into Law | State of California – Department of Justice – Office of the Attorney General.

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UK urged to act as Polymarket takes bets on whether HSBC and Lloyds will fail | Banking | The Guardian

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However, academics have warned these platforms are creating a serious moral hazard, giving market participants “an incentive to engage in corrupt, illegal, or dangerous actions in order to rig the outcome of the contract”.

From: UK urged to act as Polymarket takes bets on whether HSBC and Lloyds will fail | Banking | The Guardian.

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Assessing the McKinsey Global Payments Report

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Banks: Own trust & identity

Remember back in section 2, page 14 when McKinsey recommended banks own the Identity layer? Section 3, page 25 is the only other time they mention it:

“Issue verifiable machine credentials, manage delegated authorization and consent mechanisms, and actively shape industry standards before protocols become fixed.”
That may work in countries where the top 3-5 banks have ~90% share. They can coordinate to offer a shared credential based on their internal KYC. But in the US, the top 10 banks have <60% share with a long tail of thousands of banks. The big banks tried to create an identity bureau at EWS in 2015-2019, but never launched. I never knew why, but liability may have been a contributing factor.

For the US, this recommendation seems gratuitous. No bank has enough consumer DDA share to do this on their own and doing it as an industry already failed. Bringing in the long tail might take forever (e.g., Fednow, Zelle). The biggest eCommerce acquirers and the card networks might get there sooner. So might Apple, at least for iPhone users.

From: Assessing the McKinsey Global Payments Report.

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The 2026 Global Payments Report | McKinsey

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To navigate this transition, leaders may want to evaluate focused strategic priorities tailored to their institution’s role.

Priorities for banking institutions

Anchor trust and machine identity. Issue verifiable machine credentials and manage dynamic consent registries, using established regulatory compliance capabilities.

From: The 2026 Global Payments Report | McKinsey.

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Shortly afterwards, I got a call from a source who told me: “It’s going to be all about trust; you’ll only be able to trust what is nearest to you — what you can actually see, hear, touch.”

If that turns out to be true, it would only further the trend towards political and economic regionalisation and localisation that we are already seeing. One cyber security expert noted that clients were asking for increasingly individualised, bespoke security systems, because they don’t even trust other companies in their industry that they might be dealing with during daily business.

From: .

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The 2026 Global Payments Report | McKinsey

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Two main mechanisms account for this baseline revenue exposure:

Deposit net interest income compression ($65 billion at risk). Autonomous treasury and personal finance agents could automatically sweep idle cash into higher-yielding accounts or alternative investments, thereby reducing low-cost deposit balances that institutions rely on to maintain interest margins.
Consumer card revenue erosion ($10 billion at risk). Agents programmed to optimize merchant processing costs or consumer rewards could dynamically switch payment rails, bypass interchange fees, and automate card payoff schedules to avoid interest charges. In the United States, agentic optimization could disrupt roughly 30 percent of the $10.3 billion net card interchange pool by 2030 by routing transactions away from high-fee rails (Exhibit 4).

From: The 2026 Global Payments Report | McKinsey.

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Lloyds survey reveals 71% of UK FIs believe tokenisation will reshape financial services

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Lloyds’ 10th annual Financial Institutions Sentiment Survey, conducted between April and May 2026, showed that 71% of the 100 senior leaders surveyed across UK banks, insurers, financial sponsors and asset and wealth managers, expect tokenisation to transform how money and assets move through the financial system.

From: Lloyds survey reveals 71% of UK FIs believe tokenisation will reshape financial services.

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