Key takeaways
- Major jurisdictions now have, or are finalising, dedicated rules for stablecoins.
- Common requirements include full reserves in high-quality liquid assets, public reserve disclosures, redemption at par and AML obligations for issuers.
- The US GENIUS Act and the EU's MiCA are the two most influential frameworks.
- Rules differ in the detail, so businesses operating across borders need a jurisdiction-by-jurisdiction view.
For most of their history, stablecoins grew faster than the rules around them. That era is ending. Since 2023, the world's largest financial centres have moved from statements and consultations to binding law. This guide summarises where the major frameworks stand and what they have in common.
United States: the GENIUS Act
In July 2025, the United States enacted the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, the first federal framework for payment stablecoins. Its key features include:
- Permitted issuers only: payment stablecoins offered in the US must be issued by permitted issuers, such as subsidiaries of insured banks, federally approved non-bank issuers, or, for smaller issuers, state-qualified issuers under a state regime that meets federal standards.
- One-to-one reserves: issuers must hold reserves at least equal to outstanding tokens, in specified high-quality liquid assets such as US dollars, insured deposits and short-dated Treasury bills.
- Monthly disclosure: issuers must publish the composition of their reserves each month, with independent examination.
- No interest to holders: issuers may not pay interest or yield to holders simply for holding the stablecoin.
- AML obligations: issuers are treated as financial institutions under the Bank Secrecy Act, with requirements for AML programs, sanctions compliance and the technical ability to comply with lawful orders.
- Not a security: payment stablecoins issued under the Act are excluded from the definition of a security.
The Act takes effect on the earlier of 18 months after enactment or 120 days after regulators issue final implementing rules, so the detailed rulemaking by federal agencies is central to how it works in practice.
Separately, US businesses that transmit value, including many crypto businesses, have long been subject to FinCEN registration and Bank Secrecy Act obligations as money services businesses, as well as state money transmitter licensing.
European Union: MiCA
The Markets in Crypto-Assets Regulation (MiCA) created a single rulebook across EU member states. Its rules for stablecoins applied from 30 June 2024, and the rest of the regulation from 30 December 2024.
MiCA distinguishes two kinds of stablecoin:
| Category | What it references | Who may issue |
|---|---|---|
| E-money tokens (EMTs) | A single official currency, such as the euro or dollar | Authorised credit institutions or electronic money institutions |
| Asset-referenced tokens (ARTs) | Other assets or a basket of currencies or assets | Authorised issuers meeting MiCA requirements |
Issuers must publish a white paper, maintain reserves, offer redemption rights and meet governance requirements. Tokens deemed significant face stricter rules and supervision by the European Banking Authority.
MiCA also introduced authorisation for crypto-asset service providers (CASPs), such as exchanges, custodians and brokers, with a passport to operate across the EU. Member states could allow existing providers a transitional period of up to 18 months, ending no later than 1 July 2026.
Alongside MiCA, the EU's recast Transfer of Funds Regulation applies the Travel Rule to crypto-asset transfers. See The Travel Rule, explained.
United Kingdom
The UK requires crypto-asset businesses to register with the Financial Conduct Authority (FCA) under its money laundering regulations, and has applied the Travel Rule since September 2023. The government and FCA have been building a broader regime for crypto-assets and fiat-backed stablecoins, which brings issuance and key activities into regulation. Businesses should track FCA publications for final rules and timelines.
Singapore
The Monetary Authority of Singapore (MAS) licenses digital payment token service providers under the Payment Services Act. In 2023 it finalised a framework for single-currency stablecoins pegged to the Singapore dollar or G10 currencies and issued in Singapore, covering reserve backing, redemption at par within five business days, and disclosure. Stablecoins meeting the requirements can be labelled "MAS-regulated stablecoins".
Hong Kong
Hong Kong's Stablecoins Ordinance took effect on 1 August 2025, requiring issuers of fiat-referenced stablecoins in Hong Kong, or of Hong Kong dollar stablecoins anywhere, to be licensed by the Hong Kong Monetary Authority (HKMA). Licensed issuers must meet requirements on reserves, redemption, risk management and disclosure.
What the frameworks have in common
Despite different legal traditions, the major regimes converge on a set of shared principles:
- Full backing with high-quality, liquid reserve assets, segregated from the issuer's own funds.
- Redemption at par within a defined timeframe.
- Transparency through regular, independently verified reserve disclosures.
- Authorisation of issuers and service providers by a competent authority.
- AML and sanctions compliance, including the Travel Rule.
- Consumer protection, including clear disclosures and restrictions on misleading claims.
What this means for businesses
For businesses that accept, hold or transfer stablecoins, regulation is ultimately good news: it brings clearer rules, more trustworthy assets and easier conversations with banks and auditors. It also means:
- Choosing assets carefully, favouring stablecoins whose issuers are authorised in the markets you serve.
- Knowing your own obligations, which depend on what you do (accepting payments, custody, exchange or transfer) and where you do it.
- Respecting jurisdictional limits. Some services cannot lawfully be offered everywhere, and responsible providers adapt availability accordingly.
At Aspirations, regulation shapes product design from the start. Products only launch, and features only become available, where they can be offered lawfully.
This article is general information, not legal, tax or financial advice. Laws and regulatory guidance change frequently and vary by jurisdiction; it reflects our understanding at the time of writing. Seek qualified advice before acting on it.