In the space of five weeks, Revolut and Nubank both put stablecoins in front of their customers — and neither chose to issue the coins itself.

Their decisions point to a market in which stablecoin economics increasingly follow the customer relationship rather than the company that issues the token.

A Charter That Rules Out Issuance

On Sept. 2, the U.S. Office of the Comptroller of the Currency gave Revolut preliminary conditional approval for an American bank charter. The decision includes pages of capital requirements, conditions and further approvals.

One section addresses Revolut-branded stablecoins directly.

"The Bank will NOT be the issuer and will NOT be managing any of the reserves related to the Revolut-branded stablecoins."

The stablecoins will carry Revolut's name, but a third party will back them. According to the OCC records, Revolut's role will be limited to "marketing and providing customer access and custody through TechCo," a Revolut affiliate.

That says something important about the emerging model: Revolut and Nubank have both placed stablecoins in front of their customers without becoming issuers, and they are not alone.

Revolut Moves First With EURR

In August 2026, Revolut began a phased rollout of EURR, a euro-backed stablecoin, to eligible customers in Denmark, Poland and Portugal. Wider availability across the European Economic Area is expected later this year.

A stablecoin is designed to maintain the value of one unit of its underlying currency and is backed by cash and other safe assets. Under the European Union's Markets in Crypto-Assets (MiCA) framework — the EU's rulebook for crypto-asset issuance and services — a token pegged to a single currency is regulated as an e-money token.

EURR carries the Revolut name, but its issuer is Bridge Building S.A., the Luxembourg-based e-money institution of Bridge, which Stripe acquired in February 2025. Bridge says EURR operates on its Open Issuance platform, while Revolut's Cyprus-regulated crypto business makes the token available through its app.

"EURR connects 80 million Revolut customers directly to on-chain finance," said Emil Urmanshin, Revolut's head of crypto and new bets.

Nubank Follows With Nu Global

On Sept. 10, Nubank's parent company launched Nu Global in the United States, describing it as "a multi-currency digital account for people with global lives."

Deposits are converted into USDC or EURC, the dollar and euro stablecoins issued by Circle. Nu advertises variable annual yields of 3.50% and 2.20% respectively, alongside free transfers across more than 35 countries, initially covering Europe and Latin America.

Nubank's announcement did not name Circle; Circle announced the integration separately. The distinction matters: the coins belong to Circle, while the customer relationship — more than 140 million customers by Nubank's count — remains with Nubank.

A Familiar Structure With a Twist

The arrangement predates stablecoins. Fintech companies have long placed their brands and customer relationships on top of licensed banks that provide the regulated balance sheet underneath. Nubank itself uses this model in the United States, where Lead Bank provides its U.S. banking services and credit card.

Stablecoins are beginning to take the same form. PayPal's PYUSD is issued by Paxos Trust Company. Klarna announced KlarnaUSD on Bridge's Open Issuance platform last year. Revolut has now joined that group.

There is, however, an important difference between a sponsor-bank model and stablecoins. A card generally remains inside the program in which it issued. A stablecoin can move across public blockchains, exchanges and wallets, and between people who may never have opened an account with Revolut.

Once a stablecoin changes hands, the brand inside the original app becomes less important. The name that ultimately matters is the issuer — the entity responsible for the holder's claim.

Why Not Issue It Themselves?

In principle, Revolut was able to issue EURR itself. MiCA permits authorised credit institutions to issue e-money tokens, and Revolut Bank UAB qualifies as one. Instead, it chose to use an external issuer, and it has not publicly explained that decision. Two factors stand out.

The first is that the economics follow distribution. Stablecoin issuers earn income — largely the interest generated by the reserves backing their tokens — and then share some of that economics with the companies that bring in customers. Circle generated $668 million in reserve income during the second quarter and reported $410 million in distribution and transaction costs. Under its agreement with Coinbase, renewed in August through 2029, Coinbase retains all reserve income generated by USDC held on its platform, as well as a share of other economics.

Bridge's Open Issuance follows a similar model. Brands can earn rewards from reserves while Bridge manages reserve operations, liquidity and compliance. Neither Revolut nor Bridge has disclosed how EURR's economics are divided.

The second factor is that issuing a stablecoin is itself a regulated activity. The issuer is responsible for the reserves, redemption at face value, disclosures and regulatory oversight. Using a licensed issuer transfers much of that regulatory burden away from the customer-facing brand.

Nubank's calculation is slightly different. Nu Global is designed around moving money between more than 35 countries, and a newly created Nu-branded stablecoin would begin without an established network of users or acceptance. USDC and EURC already have that infrastructure. For a cross-border account, using an established stablecoin can therefore be an advantage.

Whose Balance Sheet Stands Behind the Token?

For holders, the balance sheet sits somewhere else. A euro held in a Revolut account represents a claim against Revolut. A EURR token held in the same app represents a claim against Bridge Building S.A., its Luxembourg-based issuer. Under MiCA, the right to redeem the token at face value rests with the issuer.

For Nu Global customers, the route back to cash runs through Nubank, while Circle's terms allow direct USDC redemption only for Circle account holders. Neither token represents a conventional bank deposit, meaning deposit-guarantee schemes generally do not apply.

Nor do Nu Global customers necessarily make a separate decision to hold crypto — once money enters the product, the balance exists as a stablecoin.

For the brand, however, the risk works differently. Layered financial structures have a known failure point. When Synapse, the technology company connecting fintech applications with partner banks, filed for bankruptcy in 2024, some customers were unable to access their funds for weeks or months. MiCA's reserve and redemption requirements are intended to reduce that kind of risk for e-money tokens, but the reputational exposure remains. If something goes wrong with EURR, Revolut's name is the one customers see.

The Infrastructure Layer Wins Either Way

Stripe and Circle sit underneath these two launches. Stripe is turning stablecoin issuance into infrastructure that companies can purchase and operate under their own brands. Circle is making its stablecoins available for other financial companies to distribute.

Each new customer-facing brand can therefore strengthen the infrastructure provider behind it. The more companies that distribute the same stablecoin, the greater its network and market relevance becomes.

Banks now face a choice. They can issue a stablecoin under their own license, controlling the reserves, the economics and the regulatory relationship — but starting with a token that nobody else may hold. Or they can put their brand on a stablecoin issued by someone else, retaining the customer relationship and negotiating a share of the economics. The second option gives customers access to an established coin and its existing network from day one, but customers also become familiar with the name of the external issuer.

Three Open Questions

The OCC decision might have been expected to describe a bank preparing to issue its own stablecoin. Instead, it describes the opposite — and the Revolut and Nubank launches point in the same direction.

Three pieces of information would make the economics clearer:

• How is EURR's reserve income divided?
• Who ultimately funds the yield offered by Nu Global?
• Who will stand behind Revolut's U.S. stablecoins, which the OCC decision does not identify, once the rules of the U.S. GENIUS Act — the federal framework for payment stablecoins — take effect?

Until those questions are answered, the practical distinction remains with the holder. A EURR holder's claim is against Bridge's Luxembourg issuer. A Nu Global customer accesses Circle's reserves through Nubank.

The brand displayed on the screen belongs to the app. But the balance sheet that ultimately makes the holder whole belongs to neither Revolut nor Nubank.

This opinion piece was originally published on LinkedIn and appeared on BitcoinKE.