Whose Money Settles? One Week, Three Balance Sheets

Between September 21 and 24, 2026, three systems gave two answers to the same question, and US rules defined a third. None chose a non-bank stablecoin. For a treasurer, the open question is whose balance sheet the money sits on.

Three Balance Sheets, One Question

Every tokenized transaction has two legs. One leg is the asset: a bond, a fund unit, a property title. The other is the money that pays for it. For years, most of the industry's attention went to the first leg. The second leg was left open.

That changed in the week of September 21, 2026. Three systems, on two continents, each named a settlement asset. The table below sets out what they named, alongside the United States, where the answer is still a proposal.

Read across the last column. That is the decision a treasury policy has to make. We set out the instrument-level differences in our earlier comparison of tokenized deposits and stablecoins. This week added the third option, and made all three concrete.

Answer One: The Central Bank's Balance Sheet

On September 21, the Eurosystem launched Pontes. The ECB (European Central Bank) describes it as the solution that "links market DLT platforms and TARGET Services to settle DLT-based wholesale transactions in central bank money." DLT is distributed ledger technology, the shared-record systems on which tokenized assets are issued.

The cash leg can settle in two ways. It can move as cash tokens on the Eurosystem's own ledger, or directly in T2, the euro area's real-time gross settlement system. Either way, the ECB states that final settlement of the cash leg is achieved once the transaction completes in T2. Pontes supports delivery versus payment and other all-or-none transactions through a hash-link protocol that synchronizes the two legs across platforms.

The ECB calls Pontes the first initiative under its program "to make central bank money fit for a tokenised future." It is a start, not a finished service. Enhanced features and longer operating hours will be introduced gradually, with full implementation expected by 2028. A separate initiative, Appia, is working on a blueprint for a wider ledger-based ecosystem, also on a 2028 horizon.

The design choice is the point. A wholesale trade settled through Pontes carries no commercial bank credit risk on the cash leg. The money is a claim on the central bank. Access is limited to eligible institutions, among them T2 participants, central securities depositories, ledger operators under the EU pilot regime and central counterparties. A corporate treasury does not connect to Pontes. Its banks, custodians and market infrastructures do.

Answer Two: Your Bank's Balance Sheet, Announced in Canada, Live in the UK

On September 22, Bank of Montreal, CIBC, National Bank of Canada, Royal Bank of Canada, Scotiabank and TD Bank Group announced that they are jointly exploring Canadian-dollar digital money, "starting with a tokenized deposits initiative." The first phase "aims to move tokenized deposits efficiently across Canadian financial institutions." The longer-term goal is to connect with other digital asset initiatives.

The announcement is exploratory. It sets no launch date and names no platform. What gives it weight is the regulatory statement that preceded it by twelve days. On September 10, Canada's banking supervisor, the Office of the Superintendent of Financial Institutions, stated: "Tokenized deposits are, for example, not legally distinct from traditional deposits." It added that "the underlying technology of a financial product or service does not determine its legal nature."

For a treasurer, that sentence carries the week's most useful principle. In Canada, the supervisor's position is that a deposit recorded on a ledger is still a deposit. It is still a liability of the bank that took it. The credit analysis a treasury already runs on its banks still applies.

Two days later, the same answer went live in the United Kingdom. On September 24, UK Finance reported that banks in the GBTD initiative had completed "the first live customer transactions using tokenised sterling deposits." The initiative's seven member banks are Barclays, HSBC UK, Lloyds Banking Group, Monzo, Nationwide, NatWest and Santander.

The transactions were ordinary, which is why they matter. Two were remortgage completions. In each, deposit funds were locked and then released automatically at completion. The third was a consumer marketplace purchase from a private seller. These are conditional payments: money that moves only when a stated event occurs. That is the capability treasurers have been shown in demonstrations for years. Here it ran on real customer balances.

UK Finance describes tokenized deposits as "digital representations of traditional commercial bank money" that "retain the trust and regulatory protections of conventional deposits." The platform was developed by Quant as shared industry infrastructure.

The next step moves toward capital markets. UK Finance says further pilots are expected over the coming months. Participating banks "will issue digital debt instruments that can be traded and settled, with coupons paid in tokenised deposits," with settlement described as delivery versus payment versus reserves, known as DvPvR. In plain terms: the security, the commercial bank money and the central bank reserves behind it move together.

Answer Three: The Issuer's Balance Sheet

On the same day, the Federal Reserve Board issued its proposals under the GENIUS Act, the federal payment stablecoin law enacted on July 18, 2025. The Board's proposals would require Board-supervised issuers to fully back their stablecoins with permissible reserve assets, "such as short-term Treasury bills," and would set standardized capital requirements. They would introduce rules for firms that safekeep reserve assets, and a tailored application process for Board-supervised banks seeking to issue. Comments close 60 days after publication in the Federal Register.

The Fed's release completes a set. The OCC issued its proposal on February 25, 2026 (Bulletin 2026-3), covering reserves, redemption, custody, risk management and capital. The FDIC proposed application procedures for its supervised banks' stablecoin subsidiaries on December 16, 2025 (FIL-59-2025), and prudential standards on April 7, 2026 (FIL-11-2026). As of September 28, 2026, the agency texts we reviewed from all three regulators are proposals, not final rules.

By statute, the Act takes effect on the earlier of January 18, 2027 or 120 days after the primary federal regulators issue final rules. We take no view on when final rules will issue. The outcome that matters for treasurers is already visible: a bank-issued payment stablecoin is becoming a defined product, with defined reserves, capital and custody.

It is a different product from a tokenized deposit. A payment stablecoin is a claim on the issuer, backed by a segregated reserve. A tokenized deposit is a claim on the bank. Our treasurer's guide to the GENIUS Act treats the stablecoin as a credit to be underwritten: issuer status, reserve quality, redemption certainty. That framing holds. The Fed's proposals fill in the detail for bank-affiliated issuers.

What the Week Actually Showed

Set the four releases side by side and one pattern stands out. None of the three systems that went live or announced this week uses a stablecoin issued outside the banking system as its settlement asset. Europe chose central bank money for wholesale markets. The United Kingdom's banks are already using commercial bank deposits in tokenized form, and Canada's largest banks are exploring the same route.

That is not a verdict against stablecoins. The US rules are designed to bring them inside a supervised perimeter, and a bank subsidiary can be an issuer. It is a statement about where the banking systems of three advanced economies are pointing their first settlement moves: toward existing claims, in new form.

The second-order consequence is for treasury policy. For years, the debate was framed as programmable money versus traditional money. That framing no longer separates the options. All three options are programmable. The UK remortgages show conditional release on commercial bank money. Pontes synchronizes delivery and payment in central bank money. A payment stablecoin is itself a token built to move on a ledger.

What differs is the counterparty. Settlement in central bank money leaves the central bank as the counterparty, and a corporate reaches it only through its banks. A treasurer holding a tokenized deposit, where the product is legally a deposit, faces the same bank credit risk as a conventional deposit. A treasurer holding a payment stablecoin faces the issuer and its reserve.

The Latin American Translation

None of this week's systems is built for a Latin American corporate treasury. Pontes serves euro-area wholesale institutions. The Canadian and UK initiatives serve domestic banks and their customers. The US rules govern issuers under US federal supervision.

The questions they raise, however, reach any treasury that banks with global groups. The Santander group, for example, is named among the market participants onboarded to Pontes and, through its UK bank, among the seven GBTD banks. The programmable features are likely to reach Latin American treasuries through relationship banks and their international networks, not through direct access to these systems.

That makes the relationship bank the point of diligence. Five questions are worth putting to each bank now, in writing:

1. What exactly will you offer us?A tokenized deposit, access to a stablecoin, or settlement that uses central bank money through your own access? Each is a different claim.
2. Whose liability is the balance?If it is your deposit, confirm it sits on your balance sheet with the same legal standing as our existing deposits. If it is a stablecoin, name the issuer and its supervisor.
3. Which jurisdiction governs it?A tokenized deposit booked in London, Toronto or New York carries that jurisdiction's legal and resolution framework, not ours.
4. What happens to locked funds if a condition fails?Conditional payments need a defined answer for the case where completion never occurs.
5. How does it reach our local accounts?Ask how a tokenized balance converts into local-currency liquidity, at what cut-off, and through which rail.

None of these questions requires a view on technology. Each is a question a treasurer already asks about any bank product. The only change is that the answers now differ by instrument, and the instruments now look alike on a screen.

A Closing Note

This week did not settle the argument between central bank money, bank deposits and stablecoins. It showed that the three will coexist, each tied to a different balance sheet. The work for a treasurer is to know which one each balance sits on before the product arrives.

Sources

All primary documents accessed September 28, 2026. Dates in the text are those of the documents cited.

• European Central Bank, Eurosystem brings central bank money to tokenised finance, press release, September 21, 2026.
• European Central Bank, Pontes, TARGET Services product page, for the settlement mechanics and eligible participants.
• TD Bank Group (joint release of BMO, CIBC, National Bank of Canada, RBC, Scotiabank and TD), Six Canadian banks explore development of a secure CAD tokenized deposit solution, September 22, 2026.
• Office of the Superintendent of Financial Institutions, Statement on Tokenized and Other Digitally Represented Deposits, September 10, 2026.
• UK Finance, UK banks complete first live customer transactions using tokenised sterling deposits, press release, September 24, 2026.
• Board of Governors of the Federal Reserve System, press release on GENIUS Act proposals (reserves and capital, custody, application process), September 24, 2026.
• Office of the Comptroller of the Currency, Bulletin 2026-3, GENIUS Act Regulations: Notice of Proposed Rulemaking, February 25, 2026.
• Federal Deposit Insurance Corporation, FIL-59-2025, proposed rulemaking on GENIUS Act application procedures, December 16, 2025.
• Federal Deposit Insurance Corporation, FIL-11-2026, proposed rulemaking on GENIUS Act requirements and standards, April 7, 2026.
• U.S. Government Publishing Office, Public Law 119-27, GENIUS Act, approved July 18, 2025, Section 20 (Effective Date).