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Compare stablecoin regulatory regimes.

Compare six stablecoin regulatory regimes by jurisdiction, token coverage, mandatory obligations, and recorded status.

Framework data last reviewed on .

Review dates differ by regime. Status and obligations reflect the recorded review date and may have changed. Obligations marked mandatory in a proposed or draft regime describe that proposal.

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Six stablecoin regulatory regimes compared
Comparison
Middle East & AfricaCBUAE PTSR

United Arab Emirates

Central Bank of the UAE (CBUAE)In Force
What it is

Federal framework for payment stablecoin issuers establishing reserve requirements, licensing pathways, and consumer protections for stablecoins pegged to the US dollar.

Comprehensive EU-wide regulatory framework for crypto-assets including E-Money Tokens (EMTs) and Asset-Referenced Tokens (ARTs), establishing authorization, reserve, and consumer protection requirements.

UK regulatory framework for fiat-backed stablecoins used for payments, covering authorization, backing assets, custody, and redemption under the updated payments regulatory perimeter.

Singapore framework for single-currency stablecoins (SCS) pegged to SGD or G10 currencies, establishing reserve, redemption, disclosure, and capital requirements under the Payment Services Act.

Licensing regime for fiat-referenced stablecoin issuers in Hong Kong under the Stablecoins Ordinance, covering reserve management, redemption, and disclosure requirements.

UAE regulatory framework for payment tokens (stablecoins) under the Payment Token Services Regulation, requiring CBUAE licensing, AED-denomination requirements, and reserve management standards.

Jurisdiction / regulator

United States

US Congress / OCC / Federal Reserve

European Union

European Banking Authority (EBA) / National Competent Authorities

United Kingdom

Financial Conduct Authority (FCA)

Singapore

Monetary Authority of Singapore (MAS)

Hong Kong SAR

Hong Kong Monetary Authority (HKMA)

United Arab Emirates

Central Bank of the UAE (CBUAE)
Who it covers
  • E-money tokens (EMT)
  • Fiat-backed tokens

Recorded requirements include: licensing; anti-money laundering / know your customer (AML/KYC).

  • E-money tokens (EMT)
  • Asset-referenced tokens (ART)
  • Fiat-backed tokens
  • Commodity-backed tokens

Recorded requirements include: licensing; anti-money laundering / know your customer (AML/KYC).

  • E-money tokens (EMT)
  • Fiat-backed tokens

Recorded requirements include: licensing; anti-money laundering / know your customer (AML/KYC).

  • E-money tokens (EMT)
  • Fiat-backed tokens

Recorded requirements include: licensing.

  • E-money tokens (EMT)
  • Fiat-backed tokens

Recorded requirements include: licensing.

  • E-money tokens (EMT)
  • Fiat-backed tokens

Recorded requirements include: licensing; anti-money laundering / know your customer (AML/KYC).

Core obligations
Licensing
  • Federal or State Charter
Reserves
  • 1:1 Reserve Backing
  • Reserve Segregation
Disclosure
  • Monthly Reserve Attestation
AML/KYC
  • BSA/AML Compliance
Consumer Protection
  • Redemption Rights
Governance
  • Risk Management
Capital
  • Capital Requirements
Licensing
  • EBA/NCA Authorization
Reserves
  • Reserve Requirements
Disclosure
  • White Paper
AML/KYC
  • AML/CFT Compliance
Governance
  • Governance Requirements
Audit
  • Independent Reserve Audit
Capital
  • Own Funds Requirement
Redemption
  • Redemption Rights
Licensing
  • FCA Authorization
Reserves
  • Backing Assets
Disclosure
  • Financial Promotions
AML/KYC
  • MLR Registration
Consumer Protection
  • Consumer Duty
Redemption
  • Redemption at Par
Licensing
  • MPI License
Reserves
  • Reserve Composition
  • Reserve Segregation & Custody
Disclosure
  • Monthly Disclosures
Capital
  • Capital Requirements
Redemption
  • Redemption Guarantee
Licensing
  • HKMA Issuer License
Reserves
  • Full Backing
Disclosure
  • Ongoing Disclosures
Governance
  • Fit & Proper
Redemption
  • Timely Redemption
Licensing
  • CBUAE License
Reserves
  • AED Reserve Requirements
AML/KYC
  • AML/CFT Compliance
Technology
  • Technology Standards
Redemption
  • Redemption Terms
Status and directionProposed

Effective date: Not recorded

Last reviewed:

In Force

Effective date:

Last reviewed:

In Force

Effective date:

Last reviewed:

In Force

Effective date:

Last reviewed:

Enacted

Effective date:

Last reviewed:

In Force

Effective date:

Last reviewed:

GENIUS Act

What it is

Federal framework for payment stablecoin issuers establishing reserve requirements, licensing pathways, and consumer protections for stablecoins pegged to the US dollar.

Jurisdiction / regulator

United States

US Congress / OCC / Federal Reserve
Who it covers
  • E-money tokens (EMT)
  • Fiat-backed tokens

Recorded requirements include: licensing; anti-money laundering / know your customer (AML/KYC).

Core obligations
Licensing
  • Federal or State Charter
Reserves
  • 1:1 Reserve Backing
  • Reserve Segregation
Disclosure
  • Monthly Reserve Attestation
AML/KYC
  • BSA/AML Compliance
Consumer Protection
  • Redemption Rights
Governance
  • Risk Management
Capital
  • Capital Requirements
Status and direction
Proposed

Effective date: Not recorded

Last reviewed:

MiCA

What it is

Comprehensive EU-wide regulatory framework for crypto-assets including E-Money Tokens (EMTs) and Asset-Referenced Tokens (ARTs), establishing authorization, reserve, and consumer protection requirements.

Who it covers
  • E-money tokens (EMT)
  • Asset-referenced tokens (ART)
  • Fiat-backed tokens
  • Commodity-backed tokens

Recorded requirements include: licensing; anti-money laundering / know your customer (AML/KYC).

Core obligations
Licensing
  • EBA/NCA Authorization
Reserves
  • Reserve Requirements
Disclosure
  • White Paper
AML/KYC
  • AML/CFT Compliance
Governance
  • Governance Requirements
Audit
  • Independent Reserve Audit
Capital
  • Own Funds Requirement
Redemption
  • Redemption Rights
Status and direction
In Force

Effective date:

Last reviewed:

FCA Crypto

What it is

UK regulatory framework for fiat-backed stablecoins used for payments, covering authorization, backing assets, custody, and redemption under the updated payments regulatory perimeter.

Jurisdiction / regulator

United Kingdom

Financial Conduct Authority (FCA)
Who it covers
  • E-money tokens (EMT)
  • Fiat-backed tokens

Recorded requirements include: licensing; anti-money laundering / know your customer (AML/KYC).

Core obligations
Licensing
  • FCA Authorization
Reserves
  • Backing Assets
Disclosure
  • Financial Promotions
AML/KYC
  • MLR Registration
Consumer Protection
  • Consumer Duty
Redemption
  • Redemption at Par
Status and direction
In Force

Effective date:

Last reviewed:

MAS SCS

What it is

Singapore framework for single-currency stablecoins (SCS) pegged to SGD or G10 currencies, establishing reserve, redemption, disclosure, and capital requirements under the Payment Services Act.

Jurisdiction / regulator

Singapore

Monetary Authority of Singapore (MAS)
Who it covers
  • E-money tokens (EMT)
  • Fiat-backed tokens

Recorded requirements include: licensing.

Core obligations
Licensing
  • MPI License
Reserves
  • Reserve Composition
  • Reserve Segregation & Custody
Disclosure
  • Monthly Disclosures
Capital
  • Capital Requirements
Redemption
  • Redemption Guarantee
Status and direction
In Force

Effective date:

Last reviewed:

HKMA Stablecoin

What it is

Licensing regime for fiat-referenced stablecoin issuers in Hong Kong under the Stablecoins Ordinance, covering reserve management, redemption, and disclosure requirements.

Jurisdiction / regulator

Hong Kong SAR

Hong Kong Monetary Authority (HKMA)
Who it covers
  • E-money tokens (EMT)
  • Fiat-backed tokens

Recorded requirements include: licensing.

Core obligations
Licensing
  • HKMA Issuer License
Reserves
  • Full Backing
Disclosure
  • Ongoing Disclosures
Governance
  • Fit & Proper
Redemption
  • Timely Redemption
Status and direction
Enacted

Effective date:

Last reviewed:

CBUAE PTSR

Middle East & AfricaCBUAE PTSR

United Arab Emirates

Central Bank of the UAE (CBUAE)In Force
What it is

UAE regulatory framework for payment tokens (stablecoins) under the Payment Token Services Regulation, requiring CBUAE licensing, AED-denomination requirements, and reserve management standards.

Jurisdiction / regulator

United Arab Emirates

Central Bank of the UAE (CBUAE)
Who it covers
  • E-money tokens (EMT)
  • Fiat-backed tokens

Recorded requirements include: licensing; anti-money laundering / know your customer (AML/KYC).

Core obligations
Licensing
  • CBUAE License
Reserves
  • AED Reserve Requirements
AML/KYC
  • AML/CFT Compliance
Technology
  • Technology Standards
Redemption
  • Redemption Terms
Status and direction
In Force

Effective date:

Last reviewed: