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Qivalis is licensed. Now its banks have work to do.

Rado Patus9 min read
  • Stablecoins
  • MiCA
  • EMT
  • DORA

Qivalis, the 37-bank euro stablecoin issuer, announced its Dutch EMI licence on 14 October. What a member bank must build and notify before distributing it.

On 14 October 2026 Qivalis announced that De Nederlandsche Bank had authorised it as an electronic money institution. Qivalis is the Amsterdam company set up by a consortium of European banks to issue a euro stablecoin under MiCA. It now counts 37 banks across 15 countries.

The licence is not the launch. Qivalis says issuance is planned "within the next months", subject to MiCA requirements and publication of its white paper. The release does not name the token or the blockchain it will run on. The original target, set in December 2025, was the second half of 2026.

Most of the coverage stops at the issuer. The more useful question sits one step down. Qivalis plans to distribute through banks, exchanges, payment service providers and market infrastructure, not directly to the public. So the work that decides whether this token reaches a client falls on the distributors, and a good share of those are the member banks themselves.

How we got here#

DateWhat happened
25 Sep 2025Nine banks announce a joint MiCA-compliant euro stablecoin issuer under DNB supervision
1 Dec 2025BNP Paribas joins
2 Dec 2025Qivalis incorporated in Amsterdam; leadership named; launch targeted for H2 2026
20 May 202625 more banks join, taking the consortium to 37
14 Oct 2026DNB authorisation as an electronic money institution announced

The founding nine were Banca Sella, CaixaBank, Danske Bank, DekaBank, ING, KBC, Raiffeisen Bank International, SEB and UniCredit. The May wave added, among others, ABN AMRO, Erste Group, Intesa Sanpaolo, Nordea, Rabobank and Bank Pekao.

The stated use cases are 24/7 cross-border payments, programmable payments, and settlement of digital assets, from tokenised securities to crypto. Qivalis says it will run a full reserve model.

Why an EMI, and why that matters to the banks behind it#

MiCA lets two kinds of entity issue an e-money token (EMT): credit institutions and electronic money institutions. The banks could each have issued directly. They chose a shared, separately licensed vehicle instead.

The EBA's response to the Commission's MiCA review gives the context. As at 1 September 2026, 39 EMTs had been issued under MiCA, 36 of them by electronic money institutions. Three credit institutions issued EMTs directly, one through a subsidiary, and the EBA noted "a proposal among a consortium of EU banks to establish a special purpose vehicle for EMT issuance".

The distinction matters because the rules differ. A bank issuing directly is not required to segregate reserves. An EMI is. Under MiCA Article 54, at least 30% of the funds received must always sit in separate accounts at credit institutions. The rest goes into highly liquid, low-risk instruments in the same currency.

For a distributing bank, three issuer-side rules shape the product:

  • Redemption at par, at any time, without a fee (Article 49). The holder's claim is against Qivalis, not against the bank that sold the token.
  • No interest (Article 50). This binds crypto-asset service providers too. Any benefit tied to how long a client holds the token counts as interest. A bank cannot pay yield on balances held in the token.
  • Significance is assessed across the whole token (Article 56). If several issuers issue the same EMT, their data is aggregated. Once three of the Article 43 criteria are met, the EBA classifies the token as significant and stricter liquidity and audit rules apply. Those criteria include more than 10 million holders and more than €5 billion in value issued.

With 37 banks as distribution channels, significance is a realistic planning scenario rather than an edge case.

The token is the easy part#

Holding a stablecoin on a balance sheet is simple. Offering it to clients is not. The obligations depend on which role the bank takes, and most banks will take more than one.

RoleWhat MiCA requiresWhat has to exist
Offering the token to clientsIssuer's written consent; compliance with Articles 50 and 53 (Art. 48(1))Distribution agreement, approved marketing materials, controls against interest-like incentives
Custody for clientsCrypto-asset service; for a bank, notification 40 working days ahead (Art. 60(1))Custody policy, a register of positions per client (Art. 75), key management, segregation
Exchange against euro or korunaCrypto-asset service, same notification routePublished pricing methodology (Art. 60(7)(g)), execution, liquidity
Transfers on behalf of clientsCrypto-asset service, same notification route; Transfer of Funds RegulationOriginator and beneficiary data attached to every transfer, including ledger addresses
All of the aboveDORA, as a credit institutionRegister of information, incident classification, resilience testing

The Article 60 notification is where a programme becomes real. It is not a form. Article 60(7) asks for a programme of operations, AML and business continuity arrangements, the technical documentation of the ICT systems and security arrangements, the segregation procedure, the custody policy, the pricing methodology for exchange and a description of how transfers will be provided. The competent authority then has 20 working days to check that the file is complete.

All of that describes systems that have to exist, or be designed in detail, before the 40-day clock starts.

Where implementations break#

From the outside this looks like adding a currency to a wallet. Inside a bank it touches five systems that were not built to talk to a public ledger.

  • Wallet model. Custodial omnibus wallets, segregated client wallets, or support for clients' own wallets. Each changes the custody policy, the Travel Rule flow and the reconciliation design. The chain is not yet public, so the design has to stay portable.
  • Redemption path. The client's claim is on Qivalis, but the client will ask its bank. The bank needs a route to buy back and redeem, and a treasury view of the euro leg. The EBA notes that MiCA sets no maximum redemption period in normal conditions, and that practice ranges from T+1 to T+4. Agree yours with the issuer before you promise one to clients.
  • Reconciliation. The client register under Article 75 sits next to the on-chain record, core banking and the general ledger. On a 24/7 instrument the books will differ at every cut-off. Breaks need owners and timings agreed in advance.
  • Travel Rule. Since 30 December 2024 every crypto-asset transfer has to carry originator and beneficiary data, including the ledger address. That means a messaging integration with counterparties, and a policy for transfers to and from self-hosted wallets.
  • DORA. Node or RPC access, wallet infrastructure, key management and blockchain analytics are all ICT services. Each goes into the register of information and the incident taxonomy. If they come from vendors, each is a third-party arrangement with exit planning.

None of this is exotic. It is the same discipline that payments teams already apply to card and instant-payment schemes. What is new is the 24/7 public ledger in the middle, and the fact that MiCA asks for the design documents up front.

For Czech and CEE subsidiaries#

Look at the member list from Prague and four names stand out. Erste Group owns Česká spořitelna. KBC owns ČSOB. Raiffeisen Bank International holds 75% of Raiffeisenbank a.s. UniCredit owns UniCredit Bank Czech Republic and Slovakia. Bank Pekao brings Poland in directly.

Membership sits at group level. The Article 60 notification does not. It goes to the competent authority of the credit institution's home Member State. For a Czech subsidiary that is the Czech National Bank, and the subsidiary files its own. A parent's readiness in Vienna, Brussels or Milan does not transfer automatically to a Czech balance sheet, Czech core banking or a Czech client base.

The CNB has been busy. By 1 July 2026 it had assessed 251 applications and notifications for crypto-asset services and granted 11 authorisations.

Two specifics for a koruna market:

  • Every retail purchase is also an FX trade. A Czech client paying in koruna for a euro token is exchanging funds for a crypto-asset. The spread is part of the pricing methodology that has to be described in the notification.
  • The currency rules do not bite. MiCA's extra limits for tokens in non-Member-State currencies (Article 58(3)) don't apply. The euro and the koruna are both official currencies of Member States.

Where this sits on the wider rails#

Qivalis is aimed at more than retail. The Eurosystem's Pontes service, live since 21 September 2026, supports payment-versus-payment against e-money tokens as well as delivery-versus-payment for tokenised securities. A bank-backed euro EMT and a central-bank settlement bridge are complementary pieces. We covered the Pontes side in Pontes is live. On the demand side, ESMA's 8 October opinion gives CASPs three months to stop servicing non-MiCA stablecoins. We covered that in ESMA's October. Compliant euro supply is arriving just as non-compliant supply is being pushed out.

What the market is offering#

Qivalis will publish its white paper and distribution terms. Custody and wallet vendors will each offer their own stack. Law firms will draft the Article 60 notification. All three are necessary. None of them owns the integration on the bank's side: wallet model, redemption route, reconciliation, Travel Rule and the DORA evidence.

How we help#

We don't issue tokens or sell a custody platform, so the design we recommend is the one that fits your stack.

  1. Stablecoin Rails Options Sprint. Fixed fee, two to four weeks. Which roles you take (offer, custody, exchange, transfer), the wallet model, the redemption and reconciliation design, and a build plan with a cost on it.
  2. CASP Compliance Stack Audit. The Article 60(7) technical file measured against what you actually run: ICT documentation, segregation, custody policy, Travel Rule integration and the DORA register of information.
  3. Build. Wallet and custody integration, Travel Rule messaging, redemption and treasury flows, and reconciliation into core banking. Senior engineers only.

The engineering is built on a decade of regulated payments delivery under PCI and GDPR, and on delivery on the EU's regulated rails. We are based in Prague, where the subsidiary question is the practical one.

If your group has signed up and your local entity has not yet scoped its part, start with a fixed-scope verdict. That's what the readiness sprints are for, or write to us at info@prodevel.com.

Sources#