# Stablecoin regulation by country: a 2026 global map > Eight major jurisdictions have enacted or finalized stablecoin-specific regulatory frameworks as of mid-2026: the United States (GENIUS Act, July 2025), the EU (MiCA, December 2024), Hong Kong (Stablecoins Ordinance, August 2025), UAE (PTSR, July 2024), Singapore (MAS SCS framework, August 2023), Japan (amended Payment Services Act, June 2023, further amended 2025), UK (framework expected 2026–2027), and Brazil (BCB resolutions, November 2025). This article maps the status, key rules, and licensing body for each. 8 min read · Updated 2026-06-09 · Topic: regulation Canonical: https://tempo.dataos.so/articles/stablecoin-regulation-by-country As of mid-2026, eight major jurisdictions have stablecoin-specific frameworks in force or in final implementation. This article maps the status and key terms of each. Rulemaking in several jurisdictions is still in progress; specifics may change. ## Summary table | Jurisdiction | Framework | Status | Key regulator | Reserve rule | Licensing | |---|---|---|---|---|---| | **United States** | GENIUS Act | Signed July 2025; rulemaking in progress | OCC (federal nonbank); Fed (bank subsidiaries); states (SCRC-certified) | 100% — cash, ≤93-day Treasuries, overnight repos, qualifying MMFs | Permitted issuer license | | **European Union** | MiCA (Titles III–IV) | In force from 30 June 2024 (stablecoins); full from 30 Dec 2024 | EBA (significant EMTs, all significant ARTs); NCAs (others); ESMA (market integrity) | 100% — min. 30% in segregated bank account; rest in low-risk liquid instruments | EU EMI or credit-institution license | | **Hong Kong** | Stablecoins Ordinance | In force from 1 August 2025 | Hong Kong Monetary Authority (HKMA) | 100% — high-quality, highly liquid, segregated assets | HKMA license | | **UAE** | Payment Token Services Regulation | Effective July 2024 (1-year transition to July 2025) | Central Bank of UAE (CBUAE) | 100% reserve backing; strict asset segregation | CBUAE license or registration | | **Singapore** | MAS Single-Currency Stablecoin (SCS) framework | In force August 2023 | Monetary Authority of Singapore (MAS) | 100%; monthly independent checks; annual audit | MAS license under Payment Services Act | | **Japan** | Payment Services Act (amended) | Stablecoin rules from June 2023; 2025 PSA Amendment Act takes full effect June 2026 | Financial Services Agency (FSA) | 100% — cash deposits at licensed Japanese banks (up to 50% in ≤3-month JGBs from June 2026) | Licensed bank, trust company, or registered money transfer agent | | **United Kingdom** | FSM Act 2000 (Cryptoassets) Regulations 2026 | Enacted Feb 2026; FCA and BoE rules pending; go-live October 2027 | FCA (conduct); Bank of England (systemic stablecoins) | TBD (FCA rules in consultation as of mid-2026) | FCA authorization required; regime not yet operational | | **Brazil** | BCB Resolution 520/2025 | In force; BCB Instruction 701/2026 adds further requirements | Banco Central do Brasil (BCB) | Fiat currency or government securities; audited financial statements required | SPSAV (Sociedade Prestadora de Serviços de Ativos Virtuais) authorization | --- ## United States **Framework:** GENIUS Act, signed **18 July 2025**. Three licensing pathways: bank subsidiaries (FDIC-insured), OCC-approved nonbank issuers, and state-qualified issuers under SCRC-certified frameworks (capped at $10B). Reserves: 100% in cash, ≤93-day Treasuries, overnight repos, or qualifying MMFs — rehypothecation banned. Monthly disclosures examined by a registered accountant required; issuers above $50B must file GAAP-audited annual statements. Paying holders interest prohibited. All issuers subject to the Bank Secrecy Act. OCC/Fed/Treasury/FinCEN rulemaking ongoing as of mid-2026. --- ## European Union **Framework:** MiCA — Regulation (EU) 2023/1114. Stablecoin rules (Titles III–IV) applied from **30 June 2024**; full regulation from **30 December 2024**. MiCA splits stablecoins into **e-money tokens (EMTs)** — single fiat peg, requiring an EU EMI or credit-institution license that passports across all 27 member states — and **asset-referenced tokens (ARTs)**, which reference any other value and face stricter requirements. EMT reserves must be 100% backed with at least 30% in a segregated bank account; significant EMTs face a **€200M daily transaction cap**. USDT is off MiCA-regulated EU exchange books since March 2025 (Tether holds no EU authorization); USDC is authorized via Circle's French ACPR EMI license (July 2024). CASPs must be licensed by a national competent authority; incumbent CASPs had until **1 July 2026** to complete authorization. --- ## Hong Kong **Framework:** Stablecoins Ordinance, in force **1 August 2025**, administered by the Hong Kong Monetary Authority (**HKMA**). Any entity that issues a **fiat-referenced stablecoin (FRS)** in Hong Kong, or issues a Hong Kong dollar-linked stablecoin anywhere, must hold an HKMA license. Capital requirements are demanding: **HK$25 million paid-up share capital**, **HK$3 million liquid capital**, and excess liquid capital covering at least 12 months of operating expenses. Reserves must be 100% backed with high-quality, segregated, bankruptcy-remote assets. Redemption must be processed within **one business day** at par. Non-compliance carries penalties up to **HK$5 million** and **seven years' imprisonment**. A transitional window for pre-existing issuers closed in early 2026. --- ## United Arab Emirates **Framework:** Payment Token Services Regulation (PTSR), CBUAE Circular No. 2/2024. Effective **July 2024**; one-year transition to **July 2025**. The PTSR covers fiat-referenced **payment tokens** across three service categories: issuance, conversion, and custody/transfer. **Dirham Payment Tokens** require a full CBUAE license; **Foreign Payment Tokens** require CBUAE registration. Only UAE-incorporated entities may apply. Algorithmic stablecoins and privacy tokens are expressly prohibited. Obligations include 100% reserve backing, white-paper approval, client-asset segregation, and AML/CFT compliance. The Abu Dhabi (FSRA) and Dubai (DFSA) financial free zones maintain parallel but separate frameworks. --- ## Singapore **Framework:** MAS Single-Currency Stablecoin (SCS) framework, finalized and in force **August 2023**, administered by the Monetary Authority of Singapore (**MAS**) under the Payment Services Act. The framework covers **single-currency stablecoins** pegged to the Singapore dollar or any G10 currency, issued by Singapore-incorporated entities. It does not currently apply to stablecoins issued outside Singapore, even if they circulate there. Key requirements for MAS-regulated SCS issuers: - **Reserve assets**: 100% of coins in circulation at all times; monthly independent checks; annual audits - **Custody**: Separate, approved custodians - **Redemption**: At par value within **five business days** - **Capital**: Minimum **S$1 million base capital** or 50% of annual operating expenses, whichever is higher - **Disclosure**: Information on the stabilization mechanism, holder rights, and audit results A stablecoin that meets these requirements and obtains MAS authorization may be labeled a "MAS-regulated stablecoin" — a designation intended to signal quality to users and counterparties. --- ## Japan **Framework:** Payment Services Act (PSA), as amended. Stablecoins regulated as **Electronic Payment Instruments (EPI)** from **June 2023**. The 2025 PSA Amendment Act takes **full effect June 13, 2026**. Under the amended PSA, fiat-collateralized stablecoins are classified as EPIs. Only **licensed banks, trust companies, and registered money transfer agents** may issue them. Intermediaries must register as Electronic Payment Instrument Trading Businesses. Original reserve rule: **100% cash deposits at licensed Japanese banks** (demand deposits). The **2025 PSA Amendment** — passed by the National Diet following an FSA expert panel report in January 2025 — relaxes this: trust-type EPI issuers may now hold up to **50%** of backing assets in **short-term Japanese government bonds** (≤3-month maturity) or early-cancellable term deposits. This brings Japan's reserve rules closer to international norms while maintaining the core principle of high-quality liquid assets. Unbacked algorithmic stablecoins remain classified as crypto-assets under the existing framework, not as EPIs. --- ## United Kingdom **Framework:** Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, enacted **4 February 2026**. **Go-live date: October 25, 2027.** The UK has created the legislative skeleton for crypto-asset regulation, but the conduct rules from the **Financial Conduct Authority (FCA)** and the prudential rules from the **Bank of England** for systemic stablecoins are still being developed. The FCA published consultations in 2025 and 2026; final rules are expected to be published in 2026 ahead of the October 2027 go-live. The Bank of England is separately consulting on rules for **systemic stablecoins** — those that could pose financial stability risks if they failed. Its consultation on a proposed prudential regime for sterling-denominated systemic stablecoins closed in February 2026; final rules are expected in **H2 2026**. For businesses: the UK regime is not yet operational. Firms that wish to offer stablecoin products in the UK are in a pre-authorization window and should monitor FCA and BoE guidance closely through 2026. --- ## Brazil **Framework:** BCB Resolution 520/2025 (stablecoin-specific); BCB Instruction 701/2026 (additional requirements). Administered by the **Banco Central do Brasil (BCB)**. Brazil's Virtual Assets Law (2022) designated the BCB as the primary regulator. BCB Resolutions 519–521 (November 2025) operationalize the framework: firms offering custody, exchange, or intermediary services must authorize as a **Sociedade Prestadora de Serviços de Ativos Virtuais (SPSAV)**. Resolution 520/2025 subjects stablecoins to the highest SPSAV scrutiny tier — platforms must verify issuer audited financials and reserve quality (fiat or government securities; algorithmic stablecoins prohibited). BCB Instruction 701/2026 adds further stablecoin requirements. In **May 2026**, Resolution 561 restricted stablecoin settlement in regulated cross-border payments, removing a rail that licensed FX firms had used. --- ## Common principles and key divergences Every framework in force shares the same floor: 100% reserve backing, asset segregation, mandatory disclosure, licensing requirements, AML/KYC obligations, and a prohibition on purely algorithmic designs. The divergences that matter for issuers: | Dimension | Where frameworks diverge | |---|---| | **Reserve composition** | Japan: historically 100% bank deposits (up to 50% JGBs from June 2026). MiCA: 30% minimum in bank accounts. GENIUS Act: no bank-deposit floor; broad Treasury-instrument basket. | | **Redemption timeline** | Hong Kong: 1 business day. Singapore: 5 business days. US: "timely" (rulemaking pending). | | **Foreign issuer access** | MiCA: local EU EMI license required, no equivalence shortcut. GENIUS Act: foreign issuers may reach US users via registered intermediaries under equivalence conditions. Singapore: currently covers only Singapore-incorporated issuers. | | **Transaction caps** | MiCA: €200M daily cap on significant EMTs. No equivalent cap in GENIUS Act, HKMA, MAS, or CBUAE frameworks. | ## The bottom line The regulatory map for stablecoins has filled in substantially since 2023. Issuers or businesses that want to operate across the US, EU, Hong Kong, UAE, Singapore, and Japan now face a stack of separate licensing obligations — with no single license that spans more than one jurisdiction's perimeter. The converging principles make frameworks broadly compatible in philosophy; the diverging details mean each market still requires its own compliance work. For a deeper look at the two frameworks with the widest reach, see [The GENIUS Act explained](/articles/genius-act-explained) and [MiCA explained](/articles/mica-regulation-explained). ## FAQ **Which countries have passed stablecoin-specific laws as of 2026?** The United States (GENIUS Act, signed July 2025), the European Union (MiCA, applicable from June–December 2024), Hong Kong (Stablecoins Ordinance, effective August 2025), and the UAE (Payment Token Services Regulation, effective July 2024) have full stablecoin-specific frameworks in force. Singapore's MAS SCS framework has been in force since August 2023. Japan's amended Payment Services Act has covered stablecoins since June 2023, with further amendments taking full effect June 2026. Brazil issued its stablecoin rules under BCB Resolution 520/2025. **What is the UK's current stablecoin regulation status?** The UK has enacted enabling legislation — the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, published February 2026 — but the FCA and Bank of England rules that will govern stablecoin issuers and CASPs in practice are still being finalized. The regime's go-live date is currently set for October 2027. **Is there a global standard for stablecoin reserves?** There is no binding global standard, but the frameworks that exist converge on common principles: 100% backing with high-quality liquid assets, segregation of reserves from issuer assets, mandatory audits or attestations, and redemption at par. The differences are in composition details — which specific assets qualify and what minimum percentages must be held in bank deposits. **Which jurisdiction has the strictest stablecoin rules?** Hong Kong has some of the most demanding capital and reserve requirements: HK$25 million paid-up capital, one-business-day redemption, and full asset segregation. MiCA's 30%-in-bank-deposits rule for EMT reserves and its €200M daily transaction cap on significant stablecoins are also notably prescriptive. Japan requires 100% reserves held as cash deposits in licensed Japanese banks (with a 2025 amendment allowing up to 50% in short-term JGBs). **Can a stablecoin issuer get a single global license?** No. Each jurisdiction requires separate authorization. An EU MiCA license provides an EU passport across 27 member states but has no recognition outside the EU. A US GENIUS Act permitted-issuer status has no equivalence in the EU, Singapore, or Hong Kong. Issuers serving multiple major markets must stack separate licenses or structure their issuance entities by region. ## Sources 1. [Gibson Dunn — Global Stablecoin Rules in Focus](https://www.gibsondunn.com/global-stablecoin-rules-in-focus-a-cross-border-guide-to-the-new-era-of-stablecoin-regulation/) 2. [HKMA — Regulatory Regime for Stablecoin Issuers](https://www.hkma.gov.hk/eng/key-functions/international-financial-centre/stablecoin-issuers/) 3. [MAS — Finalises Stablecoin Regulatory Framework (August 2023)](https://www.mas.gov.sg/news/media-releases/2023/mas-finalises-stablecoin-regulatory-framework) 4. [CBUAE — Payment Token Services Regulation Rulebook](https://rulebook.centralbank.ae/en/rulebook/payment-token-services-regulation) 5. [Skadden — Final UK Crypto Rules Are Expected in 2026](https://www.skadden.com/insights/publications/2026/04/insights-april-2026/final-uk-crypto-rules-are-expected-in-2026) 6. [Mondaq — Stablecoin Regulation: What BCB Instruction No. 701/2026 Changes](https://www.mondaq.com/brazil/financial-services/1739156/stablecoin-regulation-what-bcb-instruction-no-7012026-changes-for-the-market) --- Neutral, sourced explainer from tempowiki. Index: https://tempo.dataos.so/llms.txt