“The regulatory frameworks you were rightly waiting for — MiCAR, GENIUS, Hong Kong — now exist,” says François Masquelier, Chair of the European Association of Corporate Treasurers (EACT) and of its domestic Luxembourg member, ATEL. “‘Too early’ is quietly becoming ‘late’ if you don’t act now. And you do not need to bet the balance sheet to learn. Experiment.”
The European Union’s (EU) Markets in Crypto-Assets Regulation (MiCAR), US GENIUS Act, and others have sought to provide an immediate private sector regulatory framework for cryptocurrencies like stablecoins – which, as the name suggests, are more stable than Bitcoin (BTC) thanks to their pegging mechanism link back to real-world assets like fiat currencies.
This is commonly achieved via cash reserves or US Treasury T-Bills, purchased on a one-to-one par level with redemption mechanisms. Stablecoins are hosted on a blockchain that is reliant on the underlying distributed ledger technology (DLT) that all cryptocurrencies use. The Hong Kong Monetary Authority’s (HKMA) Regulatory Regime for Stablecoin Issuers applies there, although the mainland is more cautious.
These regulations are necessary to tame the wilder excesses of crypto, and because public sector crypto offerings that use the same underlying DLT in the form of central bank digital currencies (CBDCs) are still years away.
These should eventually arrive in the form of the digital euro, due in 2029 in an attempt to keep control of the euro money supply; the digital pound, currently being explored for the same sovereignty reasons, and perhaps the dollar. That said, most stablecoins are already denominated in US dollar (USD) and there is a political and cultural bias towards the private sector in the US.
Uses for stablecoins
The fact is though that CBDCs aren’t here yet – stablecoins are. Treasurers can use them because of the certainty they provide that a dollar is worth a dollar, making them suitable for payment applications, as well as the more common loan and trading fiat conversion end uses.
Stablecoins can realise the true value on speculative BTC trading activities and provide an on/off ramp to wider blockchain-based DLT ecosystems and decentralised finance (DeFi) applications in trade finance and other arenas. The link they provide to back to traditional finance (TradFi) applications like bank accounts, card schemes or Swift’s cross-border payment platform, for instance, is vital in that they turn crypto into a fiat option.
“MiCAR’s e-money tokenisation regime in the EU, the GENIUS Act in the US (July 2025) and Hong Kong’s Stablecoins Ordinance (August 2025), have collectively removed the single biggest blocker to stablecoin adoption, which was prior legal uncertainty. We now have that,” says Masquelier.
“We are now in a hybrid phase where production-scale infrastructure is here in terms of the technology and pilot-scale corporate adoption is slowly growing. I’d encourage more of it. The regulatory ‘trilogy’ of MiCAR, GENIUS, HKMA and other such moves around the world mean that treasurers can now transact with regulated, supervised, fully-reserved issuers. That is a game-changer for a profession whose first duty is the protection of corporate cash.”
Missing piece
As Masquelier points out, real-time treasury has been promised for a decade, and stablecoins may finally supply the missing piece – money that actually moves at the speed of data.
“Instant payment schemes (SEPA Instant, FedNow) solve domestic speed issues, but they stop at borders, at currency boundaries and often at amount limits,” he adds. “Stablecoins extend the real-time principle globally and around the clock, avoiding cut-off times.”
According to Masquelier, this provides four key benefits:
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Always-on liquidity. “Intercompany funding and cash pool rebalancing executed at 22:00 on a Sunday, ahead of Asian market opening, without waiting for correspondent banks, is possible,” notes Masquelier.
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Programmable treasury. DLT-based ‘smart contract’ functionality can automate sweeps, escrows, conditional supplier payments and reconciliation, removing manual intervention from routine flows.
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Continuous investment. According to Masquelier, idle balances moving seamlessly between stablecoins (the transactional leg) and tokenised money market funds (yield leg), can turn end-of-day cash positioning into a continuous optimisation process.
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Richer data. On-chain settlement gives instant, verifiable confirmation, feeding real-time cash visibility and aiding future AI-driven cash flow forecasting (CFF).
“The deeper shift is conceptual,” continues Masquelier. “Treasury moves from a batch discipline — cut-offs, end-of-day statements, T+2 — to a streaming discipline, continuous and increasingly automated.
“That will demand new TMS/ERP capabilities, new controls and new skills. It also converges with the rise of the ‘augmented treasurer’: AI agents executing within policy guardrails will need programmable money, and stablecoins are currently its most credible form.”
As Masquelier points out, treasurers who build that capability early will define the standard. “The others will adopt it later at higher cost – ergo start adopting stablecoins now as a means to learn about the wider and coming DLT-based future ecosystem.”
Where should treasurers start?
“As a pragmatic sequence, we at the EACT and ATEL associations that I presently chair recommend the following,” says Masquelier:
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Educate before you allocate. Build literacy in the treasury team, and involve accounting, tax, legal, compliance and IT security for digital wallets from day one – the obstacles are rarely where you expect them, so educate yourselves.
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Map your pain points. Identify corridors where current rails genuinely hurt: costly cross-border payments, trapped cash, weekend liquidity gaps. If no pain exists, no pilot is needed.
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Governance first. Adapt your treasury policy before the first transaction: approved issuers (regulated, fully reserved only), exposure caps, custody model, approval workflows, segregation of duties all need to be worked out first.
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Pilot small and measurable. One corridor, capped amounts, defined KPIs covering cost, speed, and error rate should be worked out. You also need to inform your auditors and involve your banks — many now offer regulated on/off-ramps.
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Scale on evidence, not enthusiasm.
Masquelier concludes by explaining the “golden rule” is to be neither first nor last.
“The pioneers absorb the arrows; the laggards absorb the costs,” he says. “A structured, well-governed pilot positions you exactly where a prudent treasurer should be – informed, prepared and optional-rich. Follow our adoption advice to be ready for this disruptive technology and new form of digital money.”