Skip to content

Compare stablecoin regulatory regimes.

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

Framework data last reviewed on .

Each regime lists the official sources its status and dates were checked against, the date of that check, and the date its facts become stale: after a fixed review interval, or earlier when a known event such as a consultation closing can change the status. Stale regimes are marked. This page is editorial guidance, not legal advice. Obligations marked mandatory in a proposed or enacted-but-not-in-force regime describe the rules that will apply.

Scroll within the matrix to compare all six regimes. Row labels and regime headers stay visible.

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, enacted as Public Law 119-27 on 18 July 2025. It sets reserve, redemption, disclosure, and licensing requirements for permitted payment stablecoin issuers under federal or state supervision.

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 regime for cryptoasset activities, including issuing qualifying stablecoins in the UK, made under the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026. FCA final rules for stablecoin issuance are in PS26/10. The regime commences on 25 October 2027.

Singapore policy framework for single-currency stablecoins (SCS) pegged to SGD or G10 currencies, covering reserves, redemption, disclosure, and capital. MAS finalised the policy in August 2023 and is consulting on Payment Services Act amendments to give it legal effect.

Licensing regime for fiat-referenced stablecoin issuers in Hong Kong under the Stablecoins Ordinance (Cap. 656), in operation since 1 August 2025, 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

OCC, Federal Reserve, FDIC and NCUA (primary federal payment stablecoin regulators)

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 Disclosure
AML/KYC
  • BSA/AML Compliance
Consumer Protection
  • Redemption Policy
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 directionEnacted

Stablecoin obligations apply from: Not yet, or not recorded

Instrument: Public Law 119-27 (S. 1582), dated .

In force: Not in force

Takes effect on the earlier of 18 January 2027 (18 months after enactment) or 120 days after the primary federal payment stablecoin regulators issue final implementing regulations (Sec. 20). As of 30 September 2026 the OCC, FDIC, Federal Reserve and NCUA implementing rules published in the Federal Register were proposed rules.

In Force

Stablecoin obligations apply from:

Instrument: Regulation (EU) 2023/1114, dated .

In force:

Entered into force on 29 June 2023. Titles III (asset-referenced tokens) and IV (e-money tokens) apply from 30 June 2024; the rest applies from 30 December 2024 (Art. 149). Transitional arrangements for existing service providers end no later than 1 July 2026.

Enacted

Stablecoin obligations apply from: Not yet, or not recorded

Instrument: Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, dated .

In force: Not in force

Regulated cryptoasset activities, including UK qualifying stablecoin issuance, commence on 25 October 2027. The FCA application window runs from 30 September 2026 to 28 February 2027.

Proposed

Stablecoin obligations apply from: Not yet, or not recorded

Instrument: MAS single-currency stablecoin framework (policy finalised 15 August 2023); Payment Services Act amendments proposed in consultation P015-2026, dated .

In force: Not in force

The framework has no legal effect until the Payment Services Act amendments are enacted. Consultation P015-2026 opened on 1 September 2026 and closes on 16 October 2026; subsidiary legislation will be consulted on later.

In Force

Stablecoin obligations apply from:

Instrument: Stablecoins Ordinance (Cap. 656), dated .

In force:

In Force

Stablecoin obligations apply from:

Instrument: CBUAE Payment Token Services Regulation (Circular No. 2/2024).

In force:

In effect from 31 August 2024 (one month after Official Gazette publication, Art. 42). Article 40 gave a one-calendar-year transition period for Article 2, extendable at the Central Bank's discretion.

Sources

Verified on against:

Stale from . Re-verified at least every 30 days against the official sources.

Verified on against:

Stale from . Re-verified at least every 180 days against the official sources.

Verified on against:

Stale from . Re-verified at least every 90 days against the official sources.

Verified on against:

Stale from . Consultation P015-2026 on the Payment Services Act amendments closes on October 16, 2026, which can change the recorded status. Re-verify then, and at least every 30 days.

Verified on against:

Stale from . Re-verified at least every 180 days against the official sources.

Verified on against:

Stale from . Re-verified at least every 180 days against the official sources.

GENIUS Act

What it is

Federal framework for payment stablecoin issuers, enacted as Public Law 119-27 on 18 July 2025. It sets reserve, redemption, disclosure, and licensing requirements for permitted payment stablecoin issuers under federal or state supervision.

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 Disclosure
AML/KYC
  • BSA/AML Compliance
Consumer Protection
  • Redemption Policy
Governance
  • Risk Management
Capital
  • Capital Requirements
Status and direction
Enacted

Stablecoin obligations apply from: Not yet, or not recorded

Instrument: Public Law 119-27 (S. 1582), dated .

In force: Not in force

Takes effect on the earlier of 18 January 2027 (18 months after enactment) or 120 days after the primary federal payment stablecoin regulators issue final implementing regulations (Sec. 20). As of 30 September 2026 the OCC, FDIC, Federal Reserve and NCUA implementing rules published in the Federal Register were proposed rules.

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

Stablecoin obligations apply from:

Instrument: Regulation (EU) 2023/1114, dated .

In force:

Entered into force on 29 June 2023. Titles III (asset-referenced tokens) and IV (e-money tokens) apply from 30 June 2024; the rest applies from 30 December 2024 (Art. 149). Transitional arrangements for existing service providers end no later than 1 July 2026.

Sources

Verified on against:

Stale from . Re-verified at least every 180 days against the official sources.

FCA Crypto

What it is

UK regime for cryptoasset activities, including issuing qualifying stablecoins in the UK, made under the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026. FCA final rules for stablecoin issuance are in PS26/10. The regime commences on 25 October 2027.

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
Enacted

Stablecoin obligations apply from: Not yet, or not recorded

Instrument: Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, dated .

In force: Not in force

Regulated cryptoasset activities, including UK qualifying stablecoin issuance, commence on 25 October 2027. The FCA application window runs from 30 September 2026 to 28 February 2027.

Sources

Verified on against:

Stale from . Re-verified at least every 90 days against the official sources.

MAS SCS

What it is

Singapore policy framework for single-currency stablecoins (SCS) pegged to SGD or G10 currencies, covering reserves, redemption, disclosure, and capital. MAS finalised the policy in August 2023 and is consulting on Payment Services Act amendments to give it legal effect.

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
Proposed

Stablecoin obligations apply from: Not yet, or not recorded

Instrument: MAS single-currency stablecoin framework (policy finalised 15 August 2023); Payment Services Act amendments proposed in consultation P015-2026, dated .

In force: Not in force

The framework has no legal effect until the Payment Services Act amendments are enacted. Consultation P015-2026 opened on 1 September 2026 and closes on 16 October 2026; subsidiary legislation will be consulted on later.

Sources

Verified on against:

Stale from . Consultation P015-2026 on the Payment Services Act amendments closes on October 16, 2026, which can change the recorded status. Re-verify then, and at least every 30 days.

HKMA Stablecoin

What it is

Licensing regime for fiat-referenced stablecoin issuers in Hong Kong under the Stablecoins Ordinance (Cap. 656), in operation since 1 August 2025, 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
In Force

Stablecoin obligations apply from:

Instrument: Stablecoins Ordinance (Cap. 656), dated .

In force:

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

Stablecoin obligations apply from:

Instrument: CBUAE Payment Token Services Regulation (Circular No. 2/2024).

In force:

In effect from 31 August 2024 (one month after Official Gazette publication, Art. 42). Article 40 gave a one-calendar-year transition period for Article 2, extendable at the Central Bank's discretion.

Sources

Verified on against:

Stale from . Re-verified at least every 180 days against the official sources.