Breaking the circle: A comparison of stablecoin regulatory policies in 12 countries

Author: Fairy, ChainCatcher

Editor: TB, ChainCatcher

The disruptive effect of stablecoins is continuing to expand.

From related topics that frequently appear on TikTok's hot search list, to traditional financial bloggers collectively turning to content creation, to relatives and neighbors actively inquiring about it, stablecoins seem to have become a social buzzword that permeates daily life.

At the same time, the global policy side has also ushered in a key turning point. In the past year, the attitude of many countries towards stablecoins has shifted from cautious observation to acceptance: Hong Kong's "Stablecoin Ordinance" is about to be implemented, the EU MiCA Act has officially landed, and the United States has passed the "Genius Act". Stablecoins are quietly prying the foundation of the global monetary system.

This article will systematically sort out the latest developments in stablecoin regulation in various countries and analyze the underlying logic and strategic implications of this financial change.

A table showing the global stablecoin regulatory situation

Analyzing the evolution of stablecoin policies in the world's twelve core markets

United States: State federation divided, race to layout

Policy progress speed: ★★★★

The development of stablecoins in the United States presents a dual-track advancement of "federal + state level". On the one hand, the federal government is accelerating the unification of the regulatory framework at the legislative level; on the other hand, the states are taking the lead in testing the waters and promoting the implementation of the system.

At the state level, many places have taken the lead in implementing specific laws and regulatory frameworks:

• Wyoming passed the Wyoming Stablecoin Act in 2023, established the Wyoming Stablecoin Commission, and plans to issue the state-backed stablecoin WYST on August 20, 2025.
• In 2018, the New York Department of Financial Services required stablecoin issuers to obtain a BitLicense or a trust company license and comply with strict regulations.
• California passed the Digital Financial Assets Act (DFAL) in 2023, establishing a comprehensive licensing system covering stablecoin issuers. DFAL will officially take effect in July 2026.

Regulatory legislation at the federal level is also advancing rapidly:

• The GENIUS Act was signed into law by Trump on July 19, 2025.

The bill requires: prohibiting the issuance of income-generating stablecoins, disclosing the reserve composition monthly and auditing it, and the CEO and CFO being responsible for the authenticity of the data. Issuers can choose to be regulated by the federal or state governments, and small issuers (with an issuance amount of less than $10 billion) can choose to be regulated only by the state.

• The STABLE Act was introduced in March 2025 and has been reviewed by the House of Representatives and is awaiting a vote in the Senate. The draft bill is largely identical to the GENIUS Act.

China: Hong Kong takes the lead, while the mainland waits and sees

Policy progress speed: Hong Kong ★★★★｜Mainland ★

Mainland China and Hong Kong have formed a "outpost + local" stablecoin regulatory linkage pattern: Hong Kong took the lead in establishing a mature regulatory system to accelerate the attraction of companies to settle down; while the mainland remains cautious at the policy level.

In Hong Kong, its Stablecoin Ordinance will officially come into effect on August 1, 2025.

At present, about 50 to 60 companies have expressed their intention to apply, half of which are payment institutions and the other half are large Internet platforms, most of which have Chinese backgrounds. JD.com, Standard Chartered, Ant, etc. have started relevant preparations. The industry expects that only 3 to 4 licenses will be issued in the first batch, and the entry threshold is quite high.

It is reported that the first batch of licenses may adopt an "invitation application system" rather than a unified public application, and the initial stablecoins will be mainly pegged to the Hong Kong dollar and the US dollar.

In the mainland, the country has long been in a state of "preventive suppression", but recently many provinces and cities have released signals of research and attention on stablecoins.

• On July 7, the Wuxi Municipal Party Committee proposed exploring "stable currency to empower foreign trade development" at the reform promotion meeting to expand new space for digital trade;
• On July 9, the official WeChat account of the Jinan Municipal People's Government Research Office published a special article on stablecoins written by Xinhua News Agency;
• On July 10, the Party Committee of the Shanghai State-owned Assets Supervision and Administration Commission held a central group study meeting to study the development trends and response strategies of cryptocurrencies and stablecoins;
• On July 18, the China Industrial Internet Research Institute hosted the "Stablecoin and Industrial Digital Assets Seminar".

South Korea: Attitude changes, banking alliance accelerates layout

Policy progress speed: ★★★

South Korea is experiencing a transition from "wait and see" to "enter the market". Against the backdrop of the new President Lee Jae-myung's commitment to support the development of the Korean won stablecoin, on June 10, South Korea's ruling party formally proposed the "Basic Law on Digital Assets", which intends to allow local companies with capital exceeding US$368,000 to issue stablecoins, marking a loosening of the policy level.

Currently, the eight major banks in South Korea are planning to establish a joint venture to jointly issue a Korean won stablecoin. Participating institutions include Kookmin Bank, Shinhan Bank, Woori Bank, Nonghyup Bank, Korea Development Bank, Suhyup Bank, and the Korean branches of two foreign banks, Citi and Standard Chartered. The project is jointly promoted by the eight major banks, the Open Blockchain and Decentralized Identity Association, and the Financial Supervisory Service. If approved by regulators, it is expected to go online at the end of this year or early next year.

However, current regulation is still in an uncertain state. According to Four Pillars research director 100y.eth, South Korea is currently experiencing a stablecoin bubble, and there is no clear guidance on regulation. Financial news reports almost daily that banks or companies have applied for stablecoin-related trademarks, and the stock prices of related listed companies usually rise by 15%-30% on the same day.

Thailand: Opening the floodgates of policy, testing the waters with caution

Policy progress speed: ★★★

Thailand's stablecoin policy has gradually moved from early vigilance to prudent pilots. As early as 2021, the Bank of Thailand launched an exploration of stablecoin regulation and issued preliminary guidance. Among them, stablecoins anchored to the Thai baht are regarded as "electronic money" and are regulated by the Payment Systems Act. Relevant institutions need to consult the central bank for approval before issuing; while stablecoins anchored to foreign currencies (such as USDT, USDC) are not banned, but require further supervision.

The real turning point will come in 2024. In August, Thailand set up a regulatory sandbox to allow certain service providers to experiment with cryptocurrencies.

In 2025, the scope of the pilot will be expanded rapidly:

• In January, Thailand’s finance minister told a Securities and Exchange Commission meeting that the government was considering issuing a stablecoin backed by 10 billion baht in government bonds.
• In March, the Thai Securities and Exchange Commission (SEC) approved USDT and USDC as tradable assets on the country’s regulated exchanges.
• In July, the SEC and BOT jointly launched the "National Crypto Sandbox", allowing foreign tourists to exchange digital assets (such as USDT, USDC) for Thai baht through licensed platforms for tourism consumption.

EU: unified supervision, cautious support

Policy progress speed: ★★★★★

The EU's attitude towards the development of stablecoins can be summarized as "cautious support": it fully recognizes the potential of stablecoins, but also remains highly vigilant about financial stability, regulatory arbitrage and money laundering risks.

In June 2023, the EU officially released the Markets in Crypto-Assets Regulation (MiCA), with the core goal of comprehensively regulating the crypto-asset market. Some provisions will take effect on June 30, 2024, and the stablecoin-related provisions will be fully implemented on December 30, 2024. The bill applies to the 27 EU member states and three countries in the European Economic Area (EEA), including Norway, Iceland, and Liechtenstein.

MiCA sets a high threshold for the issuance and operation of stablecoins: issuers must obtain authorization from member state regulators (such as Germany's BaFin and France's AMF) and establish a legal entity in the EU. Stablecoins that meet the "importance" standard (such as huge trading volumes) will be uniformly supervised by the European Banking Authority (EBA).

MiCA also stipulates that the daily transactions of non-euro-denominated stablecoins in any currency area shall not exceed 1 million transactions or 200 million euros. Once the limit is exceeded, the issuer must suspend the issuance of the stablecoin and submit a rectification plan within 40 working days.

Currently, the EU has issued MiCA licenses to 53 crypto companies, including 14 stablecoin issuers and 39 crypto asset service providers.

Singapore: Early start, high standards

Policy progress speed: ★★★★★

Singapore is at the forefront of stablecoin regulation. As early as December 2019, Singapore introduced the Payment Services Act, which clarified the definition and classification of payment service providers.

Subsequently, the Monetary Authority of Singapore (MAS) released the draft "Stablecoin Regulatory Framework" in December 2022 and launched public consultation, and officially launched the final version on August 15, 2023. This regulatory framework specifically applies to single-currency stablecoins (SCS) issued in Singapore and anchored to the Singapore dollar (SGD) or G10 currencies, and is included in the regulatory system as a supplementary provision of the Payment Services Act.

MAS has set a high entry threshold, and issuers must meet the following requirements:

• The capital of the stablecoin issuer shall not be less than 50% of the annual operating expenses or S$1 million;
• Stablecoin issuers are not allowed to engage in other businesses such as trading, asset management, pledge, lending, etc., nor are they allowed to directly hold shares in other legal entities;
• The scale of liquid assets that meets the normal withdrawal needs of assets or exceeds 50% of annual operating expenses.
• The reserve assets of the issuer of a stablecoin can only consist of the following extremely low-risk and highly liquid assets: cash, cash equivalents, and bonds with a remaining maturity of no more than three months.

At present, many institutions have applied to MAS for stablecoin issuance qualifications. Among them, StraitsX (XSGD issuer) and Paxos are regarded as the first demonstration cases of compliance.

UAE: Actively promote dual-track development

Policy progress speed: ★★★★★

The UAE has shown a supportive and open attitude towards stablecoin policies. In June 2024, the Central Bank of the UAE issued the Payment Token Services Regulations, which clarified the definition and regulatory framework of "payment tokens" (stablecoins).

As a federal country consisting of seven emirates, the UAE's regulatory system has a distinct "dual track" feature: the central bank is responsible for federal supervision, while the Dubai International Financial Centre (DIFC) and the Abu Dhabi Global Market (ADGM) are financial free zones with independent legal systems and regulatory powers.

Compared with the EU MiCA or Hong Kong Stablecoin Ordinance, the UAE’s new regulations are relatively broad in their definition of stablecoins, but still set certain boundaries:

• Banning the issuance of algorithmic stablecoins and privacy tokens
• Stablecoins are not allowed to pay users interest or other returns tied to the time they hold the coins

In terms of specific applications, the UAE's stablecoin market has also achieved initial results. In December 2024, AE Coin was approved by CBUAE and became the first fully regulated dirham stablecoin in the UAE.

In April 2025, Abu Dhabi sovereign wealth fund ADQ, conglomerate IHC and First Abu Dhabi Bank, the largest bank in the UAE by assets, jointly announced that they would launch a new stablecoin anchored to the dirham.

Japan: Regulation first, development to be initiated

Policy progress speed: ★★★★

Japan is at the forefront of the world in terms of stablecoin regulation and has taken the lead in completing the basic legislative framework. Its regulatory path is mainly achieved through improvements to the Payment Services Act (PSA).

In June 2022, the Japanese Parliament passed a revised version of the Payment Services Act, which will come into effect in June 2023. The revised law defines stablecoins in detail, clarifies issuing entities, and lists the licenses required to conduct stablecoin transactions. It limits stablecoin issuers to three categories: banks, trust companies, and money transfer service providers.

In March 2025, the Financial Services Agency of Japan promoted the 2025 Payment Services Act Amendment to optimize the stablecoin issuance mechanism: allowing trust-type stablecoins to use up to 50% of their reserve assets for specific low-risk instruments, such as short-term government bonds or time deposits. The law also added a special registration category for crypto intermediaries to lower the threshold for participation in over-the-counter transactions.

Russia: Mainly for trial use, still limited to external use

Policy progress speed: ★★

Russia's attitude towards stablecoins has changed significantly in recent years, from initial caution and even opposition to limited support. This change is mainly due to the strategic need for cross-border settlement and autonomous financial systems under geopolitical pressure.

In 2022, the Russian Central Bank pushed for a complete ban on cryptocurrencies. However, in July 2024, the policy direction took a key turn. The Russian Federal Parliament passed two bills to formally legalize cryptocurrency mining and allow companies approved by the central bank to use crypto assets, including stablecoins, for international settlements with overseas partners. However, in the domestic field, cryptocurrencies are still not allowed to be used as a means of payment.

In March 2025, the Central Bank of Russia issued a proposal to allow "particularly qualified" high-net-worth individuals and some companies to invest in crypto assets during a three-year pilot period to explore a more transparent and controlled market environment.

Outside the policy context, Ivan Chebeskov, head of the Ministry of Finance's Digital Financial Assets Department, publicly stated that Russia should consider launching its own sovereign stablecoin to adapt to the evolution of the global payment system.

UK: Regulation in Progress

Policy progress speed: ★★

UK policy is at a critical transition stage from framework design to legislative implementation. The relevant regulatory system is based on the Financial Services and Markets Act 2023, supplemented by secondary regulations and regulatory guidelines formulated by the Financial Conduct Authority (FCA) and the Bank of England (BoE). The Act received Royal Assent on June 29, 2023, and for the first time included "digital settlement assets" (including stablecoins) in the legal scope of regulated financial activities.

In November 2023, the UK Financial Conduct Authority announced regulatory requirements for firms that issue or custody fiat-backed stablecoins. The proposed framework will seek to apply several existing regulatory standards that currently apply to many FCA-authorized entities to the field of stablecoin activities.

In April 2025, the British government released a consultation document on the draft legislation in the field of cryptocurrency, planning to add new regulated activities, including operating crypto asset trading platforms and issuing stablecoins.

Despite the continuous progress in regulations, the Governor of the Bank of England has shown a more conservative stance. Its central bank governor Andrew Bailey has publicly stated many times that the large-scale application of stablecoins may undermine the public's trust in the national currency and even pose a systemic risk to the financial system.

Canada: Regulations are vague, but regulation is taking shape

Policy progress speed: ★★

Compared with markets such as the United States and the European Union, Canada's policies are more conservative and the local stablecoin market is developing slowly.

In December 2022, the collapse of FTX caused turmoil in the global crypto market. The Canadian Securities Regulatory Authority (CSA) subsequently tightened its policies and included stablecoins in the regulatory scope of "securities and/or derivatives."

Since 2023, CSA has successively issued two key documents, SN 21332 and SN 21333, proposing a regulatory framework for "fiat-pegged stablecoins". According to relevant regulations, stablecoin issuers must register as securities issuers, submit a prospectus, or sign a letter of commitment approved by CSA.

Last month, Canada’s banking regulator said it was ready to regulate stablecoins and that a regulatory framework was being developed.

Brazil: Strict control orientation

Policy progress speed:★

Data from the Brazilian Central Bank shows that more than 90% of the country's cryptocurrency transactions involve stablecoins, which are mainly used for cross-border payments, but this trend has also raised compliance concerns.

Gabriel Galipolo, president of the Central Bank of Brazil, said the central bank initially believed that stablecoins were popular because they provided people with a convenient way to hold US dollars. However, after in-depth research, it was found that a large number of stablecoin transactions were related to cross-border shopping, and the transaction method was opaque and could be used to evade taxes or money laundering.

To this end, the Central Bank of Brazil proposed a draft new regulation in December 2024, which intends to include stablecoins in the foreign exchange regulatory system and prohibit transfers to wallets controlled by non-Brazilian entities.

Overall, Brazil’s regulatory direction has been very clear: based on strong control, high-risk transaction scenarios are suppressed first.

Despite the tightening of regulations, traditional banks have begun to explore compliance paths. Itau Unibanco, Brazil's largest bank (with more than 55 million customers), is planning to launch a stablecoin pegged to the real. Currently, Itau is studying the relevant experience of other banks and waiting for the introduction of Brazil's stablecoin regulatory framework.