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Key facts (as of 29 October 2026)
- Common formula: private.law's comparison of eight regimes finds the same core terms in each: full backing, redemption at par and no interest to holders (private.law).
- In force: the EU, Hong Kong, Japan, the UAE and the AIFC.
- Adopted, starting 2027: the US (18 January 2027) and the UK (FCA regime from 25 October 2027).
- Framework only: Singapore. MAS finalised its framework on 15 August 2023 and consulted on Payment Services Act amendments to put it into law from 1 September to 16 October 2026 (MAS, consultation P015-2026).
| Subject | Related topic |
|---|---|
| US detail | GENIUS Act and the OCC rule |
| EU detail | MiCA |
| UK detail | UK cryptoasset and stablecoin regime |
| Redemption windows | Reserves, redemption and depeg risk |
Status
| Regime | Status |
|---|---|
| EU — MiCA | Applying to issuers since 30 June 2024. 25 EMT issuers on ESMA's register; no authorised ART issuers (ESMA register CSV, 22 Oct 2026 file) |
| US — GENIUS Act | Approved 18 July 2025. OCC final rule published 23 October 2026. Act and rule effective 18 January 2027. Offering ban for non-permitted issuers from 18 July 2028 (Act, secs. 3 and 20) |
| Hong Kong — Stablecoins Ordinance (Cap. 656) | In force since 1 August 2025. Two licences granted on 10 April 2026 (Anchorpoint Financial; HSBC) (HKMA). HKDAP phase 1 beta for institutions and professional investors since 12 August 2026 (Anchorpoint); HSBC RedCoin on PayMe since 23 October 2026 (HSBC) |
| UK — FCA PS26/10 | Final rules published 30 June 2026. Bank of England Code of Practice for systemic coins due by end-2026; FCA regime operating from 25 October 2027 |
| Singapore — MAS single-currency stablecoin framework | Framework finalised 15 August 2023, not yet in law (MAS) |
| Japan — Payment Services Act | In force since June 2023; 2025 amendments in force since 1 June 2026 |
| UAE — CBUAE Payment Token Services Regulation | Effective since 31 August 2024 (CBUAE Rulebook). VARA issuance rules in full force since 19 June 2025 (private.law) |
| Kazakhstan — AIFC | Framework since 1 January 2024; first fiat-stablecoin issuer licence to AnchorX.KZ (AFSA; date 17 June 2025 per private.law) |
Timeline
flowchart LR
A[Jun 2023: Japan PSA in force] --> B[Aug 2023: Singapore framework]
B --> C[Jan 2024: AIFC framework]
C --> D[Jun 2024: MiCA for issuers]
D --> E[Aug 2024: UAE regulation]
E --> F[Jul 2025: GENIUS Act signed]
F --> G[Aug 2025: Hong Kong ordinance]
G --> H[Jun 2026: UK final rules]
H --> I[Jan 2027: US effective]
I --> J[Oct 2027: UK regime live]Issuers, capital and reserves
| Regime | Who may issue | Minimum capital | Reserve |
|---|---|---|---|
| EU | Credit institution or e-money institution (EMT) | For an EMI, the higher of €350,000 or 2% of average outstanding e-money | At least 30% on deposit at credit institutions; rest in highly liquid instruments in the same currency |
| US | Insured-depository subsidiaries, OCC federal qualified issuers, state issuers up to US$10bn | No statutory floor; OCC rule sets at least US$5m plus an operational backstop based on 12 months' expenses | 1:1 in coins and currency, deposits, Treasuries up to 93 days, overnight repo and government MMFs (Act, sec. 4) |
| Hong Kong | HKMA licensee | Paid-up capital HKD 25m (authorised institutions exempt) | Cash, short deposits, short high-quality sovereigns, overnight reverse repo; on trust with a licensed bank custodian |
| UK | FCA-authorised issuer | Highest of £350,000, a fixed-overheads requirement or 1% of average issuance | Statutory trust under CASS 16; up to 20% with intragroup custodians |
| Singapore | Currently an MPI under the PSA | Higher of S$1m or 50% of annual operating expenses | At least 100% in cash, cash equivalents and short debt rated AA− or above |
| Japan | Bank, trust company or registered funds transfer provider | Depends on the issuer's form | Trust type: up to 50% in short Japanese or US government bonds and terminable time deposits |
| UAE | CBUAE-licensed issuer (bank only via subsidiary) | AED 15m plus 0.5% of tokens outstanding (CBUAE Rulebook, Art. 13) | Full face value, segregated, with a qualified custodian |
| AIFC | Authorised firm licensed as fiat stablecoin issuer | Not published in the framework release | At least the notional value outstanding, in segregated accounts at regulated banks or custodians |
Redemption
| Regime | Redemption window |
|---|---|
| EU | At par, any time, no fee |
| US | Within 2 business days (OCC rule, 12 CFR 15.12(c)); NYDFS T+2 (private.law) |
| Hong Kong | Within 1 business day (HKMA supervision guideline) |
| UK | By T+1, from receipt of the token (FCA, PS26/10) |
| Singapore | Within 5 business days (MAS) |
| Japan | At par; funds-transfer route caps a single transfer at ¥1m |
| UAE | By the same time on the next business day (CBUAE Rulebook, Art. 21) |
| AIFC | Redemption right; no window published |
private.law notes that the EU sets no deadline but an unconditional right, which is "stronger in normal conditions and weaker under stress", because recovery plans may impose liquidity fees, caps or suspension.
Market access
| Regime | Interest to holders | Retail access and territory |
|---|---|---|
| EU | Prohibited | Permitted via CASPs and banks; passport across the EEA; cap on non-EU-currency EMTs used for payments |
| US | Issuer may not pay interest or yield for holding the coin | Permitted; foreign issuers need a comparability determination, OCC registration and US-held reserves |
| Hong Kong | Prohibited | Only licensed coins to retail; USDT and USDC to professional investors only |
| UK | Prohibited from backing assets (also via third parties); third parties may pay own-account rewards (FCA, PS26/10 paras 10.2, 10.6) | Permitted; no passport |
| UAE | Prohibited | Foreign payment tokens may be used only to buy virtual assets |
Source for all tables: private.law, Stablecoins, comparison of eight regimes, unless a cell names another source. Cells marked with a regulator were checked against that regulator's text on 29 October 2026; unmarked cells (for example Japan's reserve rules, Hong Kong's HK$25m capital, Singapore's capital and reserve details) rest on private.law alone. Read the primary law before relying on any entry.
NoteRetail access is where regimes differ most. Hong Kong limits which tokens reach retail buyers, the UAE limits what foreign tokens can be used for, and the EU caps dollar-token payment use at scale. For cross-border businesses, the same token can be fully usable in one market and restricted in the next.
WarningThe regulation of the stablecoin is separate from the regulation of your business. A licensed token does not license the activity it pays for. Gambling, brokerage and remittance still need their own authorisations.
Illustrative example: one token, three markets
Illustrative example. The business is invented.
A PSP settles merchants in the EU, Hong Kong and the UAE. In the EU it uses USDC or EURC through an authorised CASP, because USDT is not MiCA-compliant. In Hong Kong its corporate merchants are professional investors, so USDC is available; it also tests a licensed HKD coin. In the UAE, merchants can only use foreign payment tokens to buy virtual assets, so it settles in AED through a licensed local partner. One token policy, three answers.
Q/A
Which regime matters to my business?
Usually several: the regime of the token's issuer, the regimes of the VASPs or PSPs you use, and the regimes of the markets where you operate.
Will these regimes recognise each other?
Some provide for it. The US allows comparable foreign regimes, and Singapore has proposed recognising comparable foreign coins. Mutual recognition is still limited.
Which regime is strictest on capital?
private.law argues the OCC's 12-month operational backstop is a heavier constraint than any fixed floor. Hong Kong and the UAE set the highest fixed upfront numbers.
Is there a regime that allows yield to holders?
Not from issuers in these eight. In the UK, third parties may pay their own customers rewards from their own account, but not pass on backing-pool income (FCA, PS26/10, para. 10.6).
Where do tokenised deposits fit?
Under banking law, not stablecoin regimes. See Tokenised deposits vs stablecoins.
How often does this table change?
Often. Several regimes changed in 2026 alone. Check the date on every entry.
Sources
- private.law, Stablecoins: Types and Regulation (updated 25 October 2026): https://wiki.private.law/en/stablecoins
- GENIUS Act, Public Law 119-27: https://www.govinfo.gov/content/pkg/PLAW-119publ27/html/PLAW-119publ27.htm
- ESMA, interim MiCA register: https://www.esma.europa.eu/esmas-activities/digital-finance-and-innovation/markets-crypto-assets-regulation-mica
- FCA, PS26/10 stablecoin issuance: https://www.fca.org.uk/publication/policy/ps26-10.pdf
- HKMA, granting of stablecoin issuer licences (10 April 2026): https://www.hkma.gov.hk/eng/news-and-media/press-releases/2026/04/20260410-4/
- HKMA, Guideline on Supervision of Licensed Stablecoin Issuers: https://www.hkma.gov.hk/media/eng/doc/key-functions/ifc/stablecoin-issuers/Guideline_on_supervision_of_licensed_stablecoin_issuers_eng.pdf
- Anchorpoint, HKDAP beta rollout (12 August 2026): https://anchorpoint.hk/uploads/2026/08/Anchorpoint-commences-institutional-rollout-of-HKDAP-via-Beta-Access.pdf
- HSBC, HSBC RedCoin launches (23 October 2026): https://www.about.hsbc.com.hk/news-and-media/hsbc-redcoin-launches-today
- MAS, stablecoin framework (15 August 2023): https://www.mas.gov.sg/news/media-releases/2023/mas-finalises-stablecoin-regulatory-framework
- MAS, consultation P015-2026: https://www.mas.gov.sg/publications/consultations/2026/consultation-on-proposed-amendments-to-the-payment-services-act-for-stablecoin-regulation
- CBUAE Rulebook, Payment Token Services Regulation, Art. 13: https://rulebook.centralbank.ae/en/rulebook/article-13-regulatory-capital-requirement-licensed-payment-token-issuers
- CBUAE Rulebook, Art. 21: https://rulebook.centralbank.ae/en/rulebook/article-21-issuance-and-redemption-payment-tokens
- AFSA, first stablecoin issuer licence: https://afsa.aifc.kz/afsa-grants-first-stablecoin-issuer-license/
- AFSA, stablecoin framework from 1 January 2024: https://afsa.aifc.kz/astana-financial-services-authority-afsa-introduces-stablecoin-framework/
- OCC Bulletin 2026-50: https://www.occ.gov/news-issuances/bulletins/2026/bulletin-2026-50.html
- Federal Register, OCC final rule (23 October 2026): https://www.federalregister.gov/documents/2026/10/23/2026-21706/implementing-the-guiding-and-establishing-national-innovation-for-us-stablecoins-act-for-the
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