Stablecoin regulation worldwide and the GENIUS Act

A stablecoin is a crypto-asset designed to hold a steady value against a reference asset, most often a single official currency. Because fiat-backed stablecoins work like digital cash, regulators increasingly treat their issuers more like e-money institutions or narrow banks than like technology companies.

This guide compares the main issuer regimes outside the United States and explains why the US GENIUS Act has effects far beyond US borders. It does not explain how to obtain a US licence. For crypto exchanges, custodians and brokers in the EU, see the separate guide on crypto-asset service providers under MiCA.

The international baseline

In July 2023 the Financial Stability Board published ten high-level recommendations for global stablecoin arrangements. Two of them shape almost every national regime. Users should have a robust legal claim on the issuer with timely redemption, at par into fiat for single-currency stablecoins. And an arrangement should meet all applicable requirements of a jurisdiction before it starts operating there.

National laws have since converged on a recognisable core:

Requirement	EU (MiCA, EMTs)	Hong Kong	Singapore (framework)	UK (FCA rules)	UAE (CBUAE)
Who may issue	Banks and e-money institutions	Licensed issuers (local company or authorised institution)	MAS-regulated issuers	FCA-authorised UK issuers	Licensed or registered payment token issuers
Reserve backing	Funds safeguarded; at least 30% in bank deposits	Reserve pool at least equal to par value	Reserves held to strict standards	Backing assets under statutory trust	Set by regulation
Redemption	At any time, at par, no fee	Normally within 1 business day	Within 5 business days	By end of next business day (T+1)	Set by regulation
Interest to holders	Prohibited	Prohibited	Prohibition proposed (2026)	Issuer may not pass on backing asset income	Prohibited

The table is a summary. Each regime has detailed rules on eligible reserve assets, custody, audit and disclosure that are discussed below.

European Union: e-money tokens and asset-referenced tokens

MiCA, Regulation (EU) 2023/1114, has applied to stablecoins since 30 June 2024. It splits them into two types. An e-money token (EMT) references the value of one official currency. An asset-referenced token (ART) references any other value or right, or a combination, such as a basket of currencies or a commodity.

E-money tokens. Under Article 48, only a credit institution or an electronic money institution may offer an EMT to the public or seek its admission to trading, and it must first notify a white paper. EMTs are deemed to be electronic money. Article 49 gives holders a claim on the issuer and requires issuance at par on receipt of funds and redemption at any time, at par and without a fee. Article 54 requires at least 30% of funds received to be deposited in separate accounts at credit institutions, with the rest in secure, low-risk, highly liquid assets in the same currency.

Asset-referenced tokens. An ART issuer must be an EU legal person authorised under Article 21 or a credit institution (Article 16). It must hold own funds of at least the highest of EUR 350,000, 2% of the average reserve, or a quarter of fixed overheads (Article 35), and keep a reserve legally segregated from its own estate (Article 36).

Interest ban. Articles 40 and 50 forbid issuers and CASPs from granting interest on ARTs or EMTs. Any benefit linked to how long a holder keeps the token counts as interest.

Limits on non-euro use. Article 23 requires an ART issuer to stop issuing if estimated use as a means of exchange within a single currency area exceeds 1 million transactions and EUR 200 million a day on a quarterly average. Article 58(3) applies the same mechanism to EMTs denominated in a currency that is not an official currency of a Member State. That provision matters for US dollar stablecoins circulating in the EU.

Significant tokens. Tokens that exceed thresholds such as 10 million holders or EUR 5 billion in value, among other criteria in Article 43, can be classified as significant and supervised by the EBA. For significant ARTs, the own funds percentage rises from 2% to 3% of the reserve (Article 45(5)).

Hong Kong: a licensing regime under the Stablecoins Ordinance

Hong Kong’s Stablecoins Ordinance (Cap. 656) took effect on 1 August 2025. Issuing fiat-referenced stablecoins is now a regulated activity that requires a licence from the HKMA.

According to the HKMA’s Explanatory Note on Licensing, the licence is needed to issue a specified stablecoin in Hong Kong, or to issue one anywhere that references the Hong Kong dollar. Actively marketing such an activity to the Hong Kong public also counts. The main licensing criteria are:

• Local incorporation. The applicant must be a Hong Kong company or an authorised institution incorporated outside Hong Kong. Foreign non-bank groups must set up a local subsidiary.
• Capital. Non-bank applicants need paid-up share capital of at least HKD 25 million, or other financial resources approved by the HKMA.
• Reserves. Each stablecoin type needs its own segregated reserve pool, held with a qualified custodian. Its market value must at all times be at least equal to the par value of the coins in circulation, with appropriate over-collateralisation, normally in the same currency.
• Redemption. Holders must be able to redeem at par. Valid requests should normally be processed within one business day.
• No interest. The licensee must not pay, or permit to be paid, any interest on its stablecoins, and income from managing the reserve is attributed to the issuer.

The HKMA received 36 applications in its first batch. On 10 April 2026 it granted the first two licences, to Anchorpoint Financial Limited, a joint venture of Standard Chartered Bank (Hong Kong), HKT and Animoca Brands, and to The Hongkong and Shanghai Banking Corporation. Both plan to issue Hong Kong dollar stablecoins first. The selective outcome signals that the HKMA treats this as a high bar, closer to bank licensing than to a registration.

Singapore: from framework to legislation

The Monetary Authority of Singapore finalised its stablecoin framework on 15 August 2023. It applies to single-currency stablecoins pegged to the Singapore dollar or a G10 currency and issued in Singapore. Issuers must meet reserve, capital and disclosure standards and return par value within five business days of a redemption request. Only compliant tokens may be labelled “MAS-regulated stablecoins”.

On 1 September 2026 MAS opened a consultation, closing on 16 October 2026, on amendments to the Payment Services Act 2019 to put the framework into law. The main proposals are:

• recognising a limited number of foreign-issued stablecoins regulated under a comparable foreign framework;
• allowing stablecoins jointly issued by Singapore and foreign issuers to be MAS-regulated where risks are mitigated;
• prohibiting interest on MAS-regulated stablecoins;
• requiring stress testing, recovery and orderly wind-down plans, and safeguarding of customer money received before issuance.

The consultation does not set a date for the legislation. Applicants should treat the 2023 framework as the current statement of MAS expectations.

United Kingdom: final rules ahead of a 2027 start

The UK regulates stablecoin issuance under the Financial Services and Markets Act 2000, through the Cryptoassets Regulations 2026 (SI 2026/102). The FCA’s policy statement PS26/10 sets final rules for non-systemic UK-issued qualifying stablecoins. These cover issuance, backing assets, redemption, safeguarding and disclosure, and are set to come into force on 25 October 2027 with the rest of the new crypto regime.

Key features of the FCA rules include backing assets held under a statutory trust, a permitted excess of up to 5% in the backing asset pool, and redemption by the end of the next business day. The T+1 clock now starts once know-your-customer checks are complete. Issuers may not pass interest or income from the backing assets to holders, although third parties may pay their own customers rewards from their own account, such as transaction-based rewards.

Stablecoins that HM Treasury recognises as systemic come under joint supervision by the FCA and the Bank of England. As PS26/10 summarises the Bank’s June 2026 policy statement and draft rules, a systemic issuer would face a maximum of 70% of backing in short-dated UK government debt with at least 30% in central bank deposits, redemption within T+0, capital requirements and temporary issuance limits per coin.

United Arab Emirates: dirham and foreign payment tokens

The Central Bank of the UAE regulates fiat stablecoins as “payment tokens” under its Payment Token Services Regulation, effective from 31 August 2024. Dirham payment tokens are issued by licensed issuers to UAE residents. Foreign-currency tokens are issued by registered foreign payment token issuers.

Article 2 restricts how foreign payment tokens may be used onshore: licensees may facilitate their transfer only as a means of payment for virtual assets or their derivatives. Algorithmic stablecoins and privacy tokens are prohibited. Article 12 forbids issuers from paying interest or any benefit linked to holding time, and lets the Central Bank cap volumes and customer numbers.

The GENIUS Act and its effect outside the United States

The Guiding and Establishing National Innovation for U.S. Stablecoins Act, Public Law 119-27, became law on 18 July 2025. It is discussed here only because the US dollar dominates stablecoin markets, so its rules reach issuers and intermediaries worldwide.

Effective date. Under section 20, the Act takes effect on the earlier of 18 months after enactment or 120 days after the primary federal regulators issue final implementing rules. Treasury’s August 2026 proposed rule states that the effective date is expected to be 18 January 2027.

Reserve and interest standards. Section 4 requires reserves on at least a 1 to 1 basis in cash, deposits, short-dated Treasury bills, certain overnight repurchase agreements, government money market funds and similar assets. Section 4(a)(11) forbids issuers, including foreign issuers, from paying holders any interest or yield solely for holding, using or retaining a payment stablecoin.

The foreign issuer gateway. Section 3 makes it unlawful, from three years after enactment, for a digital asset service provider to offer or sell a payment stablecoin to a person in the United States unless a permitted issuer issued it. Section 18 provides the exception for foreign issuers. They must be supervised in a jurisdiction whose regime the Treasury Secretary determines is comparable, register with the Comptroller of the Currency, hold reserves in a US financial institution sufficient for US customers’ liquidity needs unless a reciprocal arrangement provides otherwise, and not be based in a sanctioned jurisdiction.

A foreign issuer or regulator can request a comparability determination, and Treasury must decide within 210 days of a substantially complete request. Treasury must publish its justification and keep a public list of countries found comparable. Section 3(b)(2) also requires a foreign issuer’s stablecoins to be technically capable of complying with lawful orders, such as freezes.

Why this matters elsewhere. A comparability test gives foreign regulators a reason to align reserve, redemption, interest and AML rules with the US model. The interest ban, full reserve backing and short redemption windows now seen in Hong Kong, the UK, the UAE and the Singapore proposals point in the same direction. MAS’s proposal to recognise comparable foreign stablecoins mirrors the same logic from the other side.

What this means in practice

• Pick the regime by currency and market. A euro token for EU users needs an EU bank or e-money institution. A Hong Kong dollar token needs an HKMA licence wherever it is issued.
• Expect bank-grade capital and controls. Hong Kong’s HKD 25 million floor and MiCA’s ART own funds rules are minimums; supervisors also assess governance, risk management and AML systems.
• Design reserves for the strictest home. Multi-jurisdiction issuers should plan for segregated pools, same-currency reserve assets and the shortest redemption deadline that applies.
• Drop yield features. Interest or holding rewards on payment stablecoins are prohibited or proposed to be prohibited in most of the regimes covered here.
• Watch cross-border recognition. Singapore’s recognition proposal and the GENIUS Act comparability process will shape which tokens can circulate across borders.