Germany’s Commercial Bank Money Token (CBMT) initiative is progressing towards production, with a sandbox for pre-production trials now live and a target of five banks going live at launch. CBMT is a deposit token solution with Commerzbank, Deutsche Bank, DZ Bank and UniCredit involved in trials alongside large enterprises like Siemens and Evonik, with technical services providers G+D, GFT and UDPN supporting the build. European regulatory clarity remains the final hurdle, but the project has quietly resolved several of the harder technical and architectural questions that have derailed comparable consortia.
CBMT and the UK’s GBTD tokenized deposit solution are racing to become the first consortium to launch a bank token solution. Many banks already have standalone tokenized deposit solutions, and Cambodia (Bakong) and China (eCNY) have central bank-orchestrated networks.
But Germany’s consortium is at a slight disadvantage compared to standalone solutions and central bank orchestrated networks. While it is widely thought that deposit tokens are subject to the same regulations as conventional deposits, this has not been officially confirmed at the European level. In December 2025, the German Federal Financial Supervisory Authority (BaFin) formally classified CBMT as a deposit and not an e-money token, meaning MiCAR does not apply. However, European regulatory approval is still needed. There is an argument that stablecoins, which many central banks have concerns about, have greater regulatory clarity in the EU than commercial bank deposits that use similar technologies.
Against that regulatory backdrop, the structure of the project has also evolved significantly since proof of concept (PoC) trials coordinated by the German Banking Industry Committee in 2024. The initiative always envisioned tokens being deployed on multiple industry DLT networks to settle payments, but earlier iterations also had a shared bank ledger. With more banks launching standalone tokenized deposit solutions, banks want to leverage that investment rather than maintaining multiple separate solutions. Instead of a shared bank ledger, the approach pursued by UDPN implements a CBMT Bridge, an interoperability solution that connects the various tokenized core banking systems to multiple industry ledgers. For banks that do not already have a token solution, the Technical Service Provider or other suppliers can provide one. This architecture change also addresses the tricky decision explored in the PoC trials: which blockchain technology to adopt. Now industry DLTs and banks can make their own choices.
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