The spillover effect of stablecoins is continuing to expand.
From frequently appearing topics on Douyin's trending list, to content creation by traditional financial bloggers, and to active inquiries from relatives and neighbors, stablecoins seem to have become a social buzzword permeating daily life.
Meanwhile, the global policy front is experiencing a key turning point. Over the past year, many countries have shifted from cautious observation to acceptance of stablecoins: Hong Kong's Stablecoin Regulation is about to be implemented, the EU's MiCA Act has been officially enacted, and the United States has passed the GENIUS Act. Stablecoins are quietly leveraging the foundation of the global monetary system.
This article will systematically review the latest developments in stablecoin regulation across countries and analyze the underlying logic and strategic implications of this financial transformation.
A Table Showing the Global Stablecoin Regulatory Landscape
Analyzing the Policy Evolution of Stablecoins in Twelve Core Global Markets
United States: Federal and State Divide, Accelerating Layout
Policy Progress Speed: ★★★★
The development of stablecoins in the United States presents a dual-track approach of "federal + state" advancement. On one hand, the federal government is accelerating the unification of the regulatory framework at the legislative level; on the other hand, states are taking the lead in piloting and promoting institutional implementation.
At the state level, many places have already implemented specific regulations and regulatory frameworks:
- Wyoming passed the Wyoming Stablecoin Act in 2023, establishing the "Wyoming Stablecoin Commission" and planning to issue a state-supported stablecoin WYST on August 20, 2025.
- The New York Department of Financial Services has required stablecoin issuers to obtain a BitLicense or trust company permit and comply with strict regulations since 2018.
- California passed the Digital Financial Assets Law (DFAL) in 2023, constructing a comprehensive licensing system covering stablecoin issuers. DFAL will officially take effect on July 1, 2026.
Federal-level regulatory legislation is also rapidly advancing:
- The GENIUS Act was signed into effect by Trump on July 19, 2025.
The act requires: prohibiting the issuance of yield-generating stablecoins, monthly disclosure and audit of reserve composition, and CEO and CFO responsibility for data accuracy. Issuers can choose between federal or state regulation, with small issuers (issuance amount <$10 billion) able to opt for state-only regulation.
- The STABLE Act was proposed in March 2025 and has passed the House of Representatives, awaiting Senate voting. The draft content is largely similar to the GENIUS Act.
MiCA sets high thresholds for stablecoin issuance and operation: issuers must obtain authorization from national regulatory agencies (such as Germany's BaFin, France's AMF) and establish legal entities in the EU. For stablecoins that meet "importance" standards (such as those with massive trading volumes), they will be uniformly regulated by the European Banking Authority (EBA).
MiCA also stipulates that daily transactions of non-euro-denominated stablecoins in any currency zone shall not exceed 1 million transactions or 200 million euros. Once the limit is exceeded, the issuer must suspend the stablecoin's issuance and submit a rectification plan within 40 working days.
Currently, the EU has issued MiCA licenses to 53 crypto enterprises, 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, clearly defining and classifying payment service providers.
Subsequently, the Monetary Authority of Singapore (MAS) released the draft Stablecoin Regulatory Framework for public consultation in December 2022 and officially launched the final version on August 15, 2023. This regulatory framework specifically applies to single currency stablecoins (SCS) issued in Singapore and pegged to the Singapore dollar (SGD) or G10 currencies, incorporated into the regulatory system as a supplementary clause to the Payment Services Act.
MAS has set high entry barriers, and issuers need to meet the following requirements:
- Stablecoin issuers' capital shall not be less than 50% of annual operating expenses or 1 million Singapore dollars;
- Stablecoin issuers shall not engage in trading, asset management, pledging, lending, or other businesses, nor directly hold shares in other legal entities;
- Liquidity assets shall meet the scale of normal asset withdrawal or be higher than 50% of annual operating expenses.
- The reserve assets of stablecoin issuers can only consist of extremely low-risk, highly liquid assets: cash, cash equivalents, and bonds with a remaining maturity of no more than three months.
Currently, multiple institutions have applied to MAS for stablecoin issuance qualifications. Among them, StraitsX (XSGD issuer) and Paxos are considered pioneering compliant examples.
UAE: Actively Promoting, Dual-Track Approach
Policy Progress Speed: ★★★★★
The UAE has shown a supportive and open attitude towards stablecoin policies. In June 2024, the UAE Central Bank issued the "Payment Token Services Regulations," clearly defining "payment tokens" (stablecoins) and their regulatory framework.
As a federation of seven emirates, the UAE's regulatory system has a distinctive "dual-track" characteristic: the central bank is responsible for federal-level regulation, while the Dubai International Financial Centre (DIFC) and Abu Dhabi Global Market (ADGM) enjoy independent legal systems and regulatory permissions as financial free zones.
Compared to the EU's MiCA or Hong Kong's Stablecoin Regulations, the UAE's new rules have a relatively broad definition of stablecoins, but still set certain boundaries:
- Prohibit the issuance of algorithmic stablecoins and privacy tokens
- Do not allow stablecoins to pay interest or other returns to users linked to holding time
In practical application, the UAE's stablecoin market has also shown initial results. In December 2024, AE Coin was approved by CBUAE, becoming the first fully regulated dirham stablecoin in the UAE.
In April 2025, ADQ (Abu Dhabi's sovereign wealth fund), the IHC corporate group, and the UAE's largest bank, First Abu Dhabi Bank, jointly announced the launch of a new stablecoin anchored to the dirham.
Japan: Regulatory Pioneering, Development Pending
Policy Progress Speed: ★★★★
Japan is at the forefront of global stablecoin regulation and has been the first to complete 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 the revised Payment Services Act, which officially took effect in June 2023. The amended law provides a detailed definition of stablecoins, clarifies issuing entities, and lists the licenses required for stablecoin transactions. It limits stablecoin issuers to three categories: banks, trust companies, and fund transfer service providers.
In March 2025, the Japanese Financial Services Agency promoted the "2025 Payment Services Act Amendment," optimizing the stablecoin issuance mechanism: allowing trust-type stablecoins to use up to 50% of reserve assets for specific low-risk tools, such as short-term government bonds or time deposits. The law also adds a special registration category for crypto intermediaries, lowering the threshold for over-the-counter trading participation.
Russia: Mainly Exploratory, Still Limiting External Use
Policy Progress Speed: ★★
Russia's attitude towards stablecoins has significantly changed in recent years, from initial caution and even opposition to limited support, mainly due to strategic needs for cross-border settlement and an autonomous financial system under geopolitical pressure.
In 2022, the Russian Central Bank had pushed for a comprehensive ban on cryptocurrencies. However, in July 2024, there was a key policy shift. The Russian Federal Assembly passed two bills, officially legalizing cryptocurrency mining and allowing enterprises approved by the central bank to use crypto assets, including stablecoins, for international settlements with foreign partners. However, in the domestic domain, cryptocurrencies are still not permitted as a means of payment.
In March 2025, the Russian Central Bank issued a proposal to allow "specially qualified" high-net-worth individuals and some enterprises to invest in crypto assets during a three-year pilot period, exploring a more transparent and controlled market environment.
Outside the policy context, Ivan Chebeskov, head of the Digital Financial Assets Department of the Ministry of Finance, publicly stated that Russia should consider launching a national sovereign stablecoin to adapt to the evolution of global payment systems.
UK: Regulation in Progress
Policy Progress Speed: ★★
The UK policy is currently at a critical stage of transitioning from framework design to legislative implementation. The relevant regulatory system is based on the Financial Services and Markets Act 2023, supplemented by secondary legislation and regulatory guidelines from the Financial Conduct Authority (FCA) and the Bank of England. The act was given royal assent on June 29, 2023, and for the first time incorporated "digital settlement assets" (including stablecoins) into the legal scope of regulated financial activities.
In November 2023, the UK Financial Regulatory Authority published regulatory requirements for companies issuing or custodying fiat-backed stablecoins. The proposed framework will seek to apply several existing regulatory standards currently applicable to many FCA-authorized entities to the stablecoin activity domain.
In April 2025, the UK government released a consultation document on cryptocurrency legislation, planning to add regulated activities, including operating crypto asset trading platforms and stablecoin issuance.
Despite ongoing regulatory progress, the Bank of England's governor has shown a more conservative stance. Governor Andrew Bailey has repeatedly stated publicly that widespread stablecoin adoption could undermine public trust in the national currency and even pose systemic risks to the financial system.
Canada: Vague Regulations, Regulation in Formation
Policy Progress Speed: ★★
Compared to markets like the US and EU, Canada's policy is more conservative, with slow local stablecoin market development.
In December 2022, the FTX collapse triggered global crypto market turbulence, and the Canadian Securities Administrators (CSA) subsequently tightened policies, incorporating stablecoins into the regulatory scope of "securities and/or derivatives".
Starting from 2023, CSA successively issued two key documents, SN 21332 and SN 21333, proposing a regulatory framework for "fiat-pegged stablecoins". According to the regulations, stablecoin issuers need to register as securities issuers, submit prospectuses, or sign commitments approved by CSA.
Last month, Canadian banking regulators stated that they are ready to regulate stablecoins, with the regulatory framework currently being developed.
Brazil: Strict Control Direction
Policy Progress Speed: ★
Brazilian Central Bank data shows that over 90% of the country's crypto transactions involve stablecoins, primarily used for cross-border payments, but this trend has also raised compliance concerns.
Brazilian Central Bank Governor Gabriel Galipolo stated that the central bank initially believed stablecoins were popular because they provided people with a convenient way to hold US dollars. However, after in-depth research, they discovered that a large number of stablecoin transactions were related to cross-border shopping, with opaque transaction methods that could potentially be used for tax evasion or money laundering.
Therefore, the Brazilian Central Bank proposed a new draft regulation in December 2024, aiming to incorporate stablecoins into the foreign exchange regulatory system and prohibit transfers to wallets not controlled by Brazilian entities.
Overall, Brazil's regulatory direction is very clear: prioritizing strict control and suppressing high-risk trading scenarios.
Despite the tightening regulations, traditional banks are beginning to explore compliant paths. Brazil's largest bank, Itau Unibanco (with over 55 million customers), is planning to launch a stablecoin pegged to the real. Currently, Itau is studying the experiences of other banks and waiting for the release of Brazil's stablecoin regulatory framework.
