Stablecoin regulation: the international picture

A stablecoin issued in the United States can be bought on an exchange in Brazil and transferred to a wallet in Asia within minutes. The rules surrounding it, however, are national. Each country decides who may issue, which reserves are accepted and what exchanges may offer.

This article shows how seven jurisdictions approach the subject, based on legal texts and regulators’ announcements, with the date of each piece of information. How stablecoins work is explained in What stablecoins are and how they hold their value. The difference between them and central bank digital currencies is covered in Stablecoins versus central bank digital currencies.

The international starting point

There is no global law. There are recommendations. In July 2023, the Financial Stability Board (FSB), which brings together G20 financial authorities, published ten recommendations for global stablecoins. Among them: that authorities cooperate with one another and that, for tokens pegged to a single currency, redemption be at face value (FSB, July 2023).

Adoption has advanced, but unevenly. According to a survey by the Bank for International Settlements (BIS), 45% of jurisdictions had rules for stablecoins and other crypto assets at the end of 2024, up from 35% a year earlier, and another 22% were developing them (BIS Papers No. 159, 2025). In October 2025, the FSB assessed that regulation of global stablecoins was lagging, that few countries had final frameworks and that the differences between them create room for regulatory arbitrage, when companies set up where the rules are lighter (FSB, October 2025).

What almost all of them require

Despite their differences, the regimes analyzed here repeat four requirements:

• License. Only authorized entities may issue. In several countries, only banks or payment institutions.
• Full reserves. For each token, assets of at least the same value, generally cash and short-term government bonds.
• Redemption at face value. The holder has the right to exchange the token for official currency, one-to-one, within a set period.
• No interest. The issuer may not pay a return to those who merely hold the token. The rationale is to keep the stablecoin as a means of payment, not an investment.

What changes from one country to another are the details: the redemption deadline, the accepted assets, who supervises and, above all, how to treat tokens issued abroad.

United States: law passed, rules under construction

The GENIUS Act (Public Law 119-27) was signed into law on July 18, 2025. Under the text, only an authorized issuer may issue a payment stablecoin in the US. The law prohibits issuers from paying any form of interest or yield merely for holding, using or retaining the token, gives holders priority over reserves in the event of insolvency and allows smaller issuers, with up to US$10 billion outstanding, to opt for a state regime similar to the federal one (GENIUS Act). The list of accepted reserves is in What stablecoins are.

The provision that most affects the market is section 3. Starting three years after enactment, digital asset service providers, such as exchanges, may not offer or sell stablecoins from unauthorized issuers to persons in the US. Tokens from foreign issuers may only be offered if the issuer has the technical capability to comply with lawful orders, such as freezes. The US Treasury places that date at July 18, 2028 (US Treasury, August 17, 2026).

The law’s general effective date is the earlier of 18 months after enactment and 120 days after regulators’ final rules. The Treasury treats January 18, 2027, as the expected effective date. As of October 8, 2026, the implementing rules were still proposals:

• The OCC, which supervises national banks, presented its proposal on February 25, 2026 (OCC, February 2026). In August, the agency’s head, Jonathan Gould, said the final rule would be out by November (OCC, August 19, 2026).
• The Treasury opened a consultation in August 2026 on what counts as issuing, offering or selling a stablecoin “in the United States”.
• The Federal Reserve proposed, on September 24, 2026, rules on reserves, capital and custody and an authorization process for issuers under its supervision (Federal Reserve, September 24, 2026).

European Union: MiCA already in application

The European crypto-assets regulation, MiCA, has applied its stablecoin rules since June 30, 2024, and the rest since December 30, 2024 (MiCA, art. 149). It is the oldest regime among the major economies.

MiCA calls a stablecoin pegged to a single official currency an e-money token (EMT). Under Article 48, only a bank or an authorized electronic money institution, with a crypto-asset white paper notified to the regulator, may offer such a token to the public or seek its admission to trading in the EU. EMTs are treated as electronic money (MiCA, art. 48). Article 50 prohibits issuers and service providers from paying interest on these tokens and defines interest broadly, including any reward linked to the length of time the token is held (MiCA, art. 50).

For exchanges, the consequence is direct. According to an official answer published by ESMA, the European markets authority, a platform that lists an EMT from an issuer not authorized under MiCA is considered responsible for seeking its admission to trading, which has been prohibited since June 30, 2024 (ESMA, Q&A 2404). And the transition period for providers already operating before MiCA ended, at the latest, on July 1, 2026 (MiCA, art. 143).

The IMF notes that MiCA also separates “significant” stablecoins, supervised at the European level, from others, supervised by member states, and requires high-quality, liquid and diversified reserves (IMF, Understanding Stablecoins, 2025).

United Kingdom: final rules, in effect in 2027

The United Kingdom created the regulated activity of issuing “qualifying stablecoins” through the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026. According to the Financial Conduct Authority (FCA), the conduct regulator, the full regime starts on October 25, 2027, and the application window for authorization runs from September 30, 2026, to February 28, 2027 (FCA, regime overview).

Final rules for non-systemic issuers came out in June 2026 (FCA, PS26/10). The main points:

• Reserve assets are held in a statutory trust for the benefit of holders, separate from the issuer’s own assets.
• Reserves may only be held in assets in the same currency as the token.
• Any holder may redeem any amount by the end of the following business day (T+1), counted from when the issuer receives the token, after identity checks.
• The issuer may not pass on reserve interest to holders. Third parties may give rewards from their own resources, for example for usage.

Sterling stablecoins that grow large enough to become systemic also come under Bank of England supervision. In June 2026, the bank replaced the idea of per-person holding limits with a temporary issuance cap per stablecoin and confirmed an emergency liquidity facility for these issuers (Bank of England, June 22, 2026). According to the FCA’s summary, the cap is £40 billion per stablecoin, and reserves must be at least 30% in central bank deposits and at most 70% in UK government bonds with less than six months to maturity.

Hong Kong: licenses since 2026

In Hong Kong, the Stablecoins Ordinance (Cap. 656) has been in force since August 1, 2025. Since then, issuing in Hong Kong a stablecoin pegged to an official currency, or issuing abroad a stablecoin pegged to the Hong Kong dollar, requires a license from the monetary authority, the HKMA (HKMA, issuer regime).

The HKMA’s supervisory guideline requires the market value of reserves to be, at all times, at least equal to the face value of tokens in circulation. Valid redemption requests must be met at face value, without an unreasonable fee, as a rule within one business day. The issuer may not pay interest, and holders retain rights over the reserves even if the issuer fails (HKMA, supervisory guideline).

The first two licenses were granted on April 10, 2026, to Anchorpoint Financial and HSBC (HKMA, April 10, 2026). In June, the government said there had been 36 applications in the first round, that new licenses would be very limited in number and that issuance could begin as early as mid-2026 (Hong Kong Government, June 10, 2026). The editorial team has not confirmed in an official source whether issuance has begun.

Singapore: the 2023 framework becoming law

The Monetary Authority of Singapore (MAS) finalized its framework in August 2023. It applies to single-currency stablecoins pegged to the Singapore dollar or a G10 currency and issued in the country. The issuer must return the face value within five business days of a redemption request, maintain minimum capital and disclose reserve audits. Only those who meet all requirements may use the “MAS-regulated stablecoin” label (MAS, August 2023).

On September 1, 2026, MAS opened a consultation to give this framework the force of law, through changes to the Payment Services Act. The proposal includes banning interest, requiring stress tests and orderly wind-down plans, and recognizing a limited number of foreign stablecoins from comparable regimes, mainly for cross-border wholesale payments. The consultation runs until October 16, 2026, so the changes are not yet in force (MAS, September 1, 2026).

Japan: the 2023 pioneer

Japan amended its Payment Services Act in June 2022, and the rules took effect on June 1, 2023 (FSA, June 2023). The Financial Services Agency (FSA) requires the issuer to be a bank, a funds transfer service provider or a trust company and to guarantee redemption at face value. Those who intermediate stablecoins need their own registration (FSA, 2022).

The official register shows the practical effect. On August 27, 2026, there were two registered intermediaries in the country, SBI VC Trade and Coincheck, both offering USDC among their tokens. The list itself warns that these instruments are not legal tender guaranteed by the government and that their price may fluctuate (FSA, list of August 27, 2026). According to the IMF, a further 2025 amendment will, when it takes effect, also allow reserves in time deposits and government bonds of up to three months. The editorial team has not confirmed the effective date of that change.

Brazil: rules for those who offer

Brazil took a different path. Instead of creating a license for issuers, the Banco Central do Brasil (Brazil’s central bank) regulated virtual asset service providers, such as exchanges, in three resolutions of November 10, 2025, in force since February 2, 2026:

• BCB Resolution No. 519 covers applications for authorization to operate.
• BCB Resolution No. 520 defines how providers operate and contains the rules on stablecoins.
• BCB Resolution No. 521 brings some stablecoin transactions into the foreign exchange market, a topic explained in What stablecoins are. Some of its provisions only took effect on May 4, 2026.

Resolution 520 defines a stablecoin as a virtual asset backed by reserve assets to maintain a value linked to an official currency. Reserve assets, for this purpose, are the currency itself and the government bonds of the government that issues it. Before offering a stablecoin, the exchange must assess, among other points, the token’s regulatory standing in the issuer’s country, the quality of the stabilization mechanism, the evidence that the reserves exist, the audited financial statements and, where available, the issuer’s credit rating. It must also disclose its selection criteria. And offering stablecoins whose reserves are controlled by algorithms is prohibited (art. 65).

In practice, the Brazilian rule does not change the token or bind the foreign issuer. It defines what the company serving you in Brazil may offer and how it must analyze it.

Comparison in a table

Situation as of October 8, 2026, according to the sources cited.

Jurisdiction	Main rule	Status	Focus
US	GENIUS Act (2025)	Law enacted; expected effective date January 18, 2027; rules proposed	Issuers and exchanges
European Union	MiCA	In application since June 30, 2024	Issuers and service providers
United Kingdom	Cryptoassets Regulations 2026 and FCA rules	Final rules; regime starts October 25, 2027	Issuers
Hong Kong	Stablecoins Ordinance (Cap. 656)	In force since August 1, 2025; two licenses in April 2026	Issuers
Singapore	MAS framework (2023)	Law under consultation until October 16, 2026	Issuers
Japan	Payment Services Act	In force since June 1, 2023	Issuers and intermediaries
Brazil	BCB Resolutions 519, 520 and 521	In force since February 2, 2026	Service providers

What this means for you

• Regulation is not a guarantee. It reduces risks, but does not prevent a loss of peg or an issuer’s failure. The loss can be total.
• The same token may have a different status in each country. A stablecoin accepted in one jurisdiction may not be authorized in another, which may limit where it is traded.
• Redemption rights vary. Under MiCA, the issuer must redeem at the holder’s request, at any time and at face value (MiCA, art. 49); the UK, Hong Kong and Singapore also set redemption deadlines. Outside these regimes, generally only large verified clients redeem directly with the issuer. The comparison between USDT and USDC shows this in practice: USDT versus USDC: mechanisms, reserves and risks.
• Dates change. Several rules cited here were still under consultation. Check the status on the regulator’s website before making decisions based on them.

Key takeaways

• The regimes converge on licensing, full reserves, redemption at face value and a ban on interest, but diverge on deadlines, accepted assets and treatment of foreign tokens.
• The European Union, Japan and Hong Kong already apply their rules. The US and the UK have laws passed with full effect expected in 2027. Singapore is still turning its framework into law.
• Brazil regulates exchanges: since February 2026 they must analyze each stablecoin before offering it, and algorithmic ones are banned.
• According to the FSB, implementation of the international recommendations is still uneven, which keeps room for arbitrage between countries.