Stablecoin Regulation Tracker

The EU regulates stablecoins under MiCA as e-money tokens (EMTs) and asset-referenced tokens (ARTs). The stablecoin provisions applied from 30 June 2024, requiring issuers to be authorised, hold high-quality liquid reserves, and honour redemption at par.

• EMT/ART issuers must be authorised EU entities (credit or e-money institutions for EMTs).
• Reserve, custody and redemption-at-par requirements; significant tokens face extra caps and oversight.
• Non-euro stablecoins used widely as means of payment face transaction limits.

Hong Kong operates a licensing regime for fiat-referenced stablecoin issuers under the HKMA, with reserve, redemption and governance requirements. Licensing of the first issuers has been a closely watched process.

• Fiat-referenced stablecoin issuers must be HKMA-licensed.
• Full backing in high-quality liquid reserves and redemption at par required.
• Early licence applicants include major banks and payment firms.

Japan recognises fiat-backed stablecoins as 'electronic payment instruments' under its amended Payment Services Act. Issuance is limited to licensed banks, trust companies and registered funds-transfer operators, with redemption guarantees.

• Only banks, trust companies and licensed money-transfer firms may issue.
• Yen-denominated stablecoins (e.g. JPYC) and bank pilots have advanced under this regime.
• Strong redemption and reserve protections for holders.

Singapore's MAS finalised a framework for single-currency stablecoins (SCS) pegged to the SGD or G10 currencies, with reserve, capital and redemption standards. Compliant tokens may be labelled 'MAS-regulated'.

• Applies to single-currency stablecoins issued in Singapore above a size threshold.
• High-quality reserve assets, capital requirements, and redemption at par within five business days.
• Only compliant issuers may market a stablecoin as MAS-regulated.

The federal GENIUS Act establishes a framework for payment stablecoins, with permitted issuers, full reserve backing and redemption requirements, and a role for both federal and state regulators. Implementing rulemaking by the OCC, FDIC and others is ongoing, alongside established state regimes such as New York's.

• Payment stablecoins must be fully reserved in high-quality liquid assets, with redemption at par.
• Dual federal/state pathway for permitted issuers; implementing rules being written.
• Separate market-structure legislation (e.g. CLARITY Act) and yield rules have been debated.

South Korea is developing legislation covering stablecoins, with debate over whether issuance should be bank-led. Draft bills would place stablecoins and related digital assets under financial regulation, with the Bank of Korea weighing financial-stability implications.

• Draft bills would bring stablecoins under a dedicated financial framework.
• Debate over bank-led vs broader issuance of won-denominated stablecoins.
• Bank of Korea has raised financial-stability and monetary-policy concerns.

The UK is finalising its regulatory regime for fiat-backed stablecoins used in payments, split between FCA conduct rules and Bank of England oversight of systemic stablecoins. Consultations have covered backing, redemption, and whether to cap individual holdings.

• FCA to regulate issuance and custody; Bank of England to oversee systemic payment stablecoins.
• Proposals have included holding limits, later reconsidered after industry feedback.
• Final rules expected as the regime moves from consultation to implementation.