Token-Based Remuneration: A Labour Strategy That Is Already a Reality

Token-Based Remuneration: A Labour Strategy That Is Already a Reality

Imagine a restaurant chain seeking to reward its kitchen and front-of-house staff after an especially intense high season. Rather than opting for a conventional bonus, it chooses to deliver part of this remuneration in the form of digital tokens. These tokens can be redeemed for company-related benefits, such as priority access to new opportunities, training programmes, or even participation in corporate decision-making processes.

Far from being a futuristic whim, this initiative is already on the table for numerous companies seeking innovative ways to remunerate, retain, and align values with their workforce. But is it actually possible?

Until recently, the answer was a clear (and negative) one. Article 26.1 of the Spanish Workers’ Statute defines salary as "all the economic compensation received by workers, whether in cash or in kind." Article 29.4 further states that “salary payments may be made by the employer in legal tender or by cheque or other similar means of payment through credit institutions.”

This implied that the use of cryptocurrencies—being neither legal tender nor backed by financial institutions—could only be considered remuneration in kind and, therefore, subject to the 30% cap over total salary.

However, the regulatory landscape has evolved, and with it, the legal possibilities. The MiCA Regulation defines “crypto-asset” as a digital representation of a value or a right that can be transferred and stored electronically using distributed ledger technology or similar. Among these, e-money tokens have emerged strongly—assets whose value is pegged to legal tender (e.g. EURC or USDC). Unlike other crypto-assets, these meet the requirements set out in the Workers’ Statute and thus may be considered remuneration in cash rather than in kind, thereby avoiding the 30% limitation.

Beyond regulatory aspects, the advantages for employers are significant. This form of remuneration offers an innovative way to reward performance, fostering behaviours aligned with corporate culture. Some tokens, in addition to their economic value, grant access to rights and benefits within the organisation, thus creating a sense of emotional connection and belonging. The inherent transparency and traceability of the underlying technology make it possible to design flexible, controllable redemption systems that are attractive to both employers and employees.

Nevertheless, the model is not without its challenges. Firstly, the price volatility of many crypto-assets (with the exception of e-money tokens) may affect the real value of the compensation, generating economic uncertainty. Secondly, the regulatory framework remains unstable and subject to ongoing changes, which may hinder implementation. Thirdly, acceptance is still limited: employees must either manage their own electronic wallets or rely on an authorised third-party custodian—an adjustment that not all workforces may be willing or ready to embrace.

Accordingly, any company intending to implement this type of remuneration must do so with a well-defined strategy. It is crucial to design a comprehensive incentive scheme specifying the requirements, objectives or behaviours to be rewarded, the value assigned to the issued tokens, and the terms of delivery. The system must be transparent, easily comprehensible, and include a clearly defined and documented redemption process.

Tailoring recognition to employees’ interests may enhance engagement—especially when short- and long-term incentives are combined. Additionally, a system for monitoring and evaluation will allow the company to assess the programme’s effectiveness and adjust it when necessary.

The use of stablecoins, such as e-money tokens, stands out as the most viable short-term option due to their lower volatility and greater legal certainty. Their capacity to integrate technological innovation with legal safeguards opens the door to new ways of conceiving labour compensation.

Now is the time to take a step forward. Companies that embrace flexible and modern remuneration models will be better positioned to attract and retain talent. The future of remuneration is already here—and it is measured in tokens.

Mónica Cid Murillo, Partner, Employment
act legal Spain