Global stablecoin regulation, November 2026.
Eight jurisdictions now set the terms for dollar and local-currency stablecoins. Here is where each stands, what it requires, and what it means for builders.
| Jurisdiction | Instrument | Status (Nov 2026) | On-chain control mandate |
|---|---|---|---|
| United States | GENIUS Act | Law; effective by 18 Jan 2027 | Freeze, seize and burn capability |
| European Union | MiCA (e-money tokens) | In force | None mandated |
| United Kingdom | FCA regime | Rules final; starts 25 Oct 2027 | None identified |
| Singapore | MAS framework | Implementing consultation closed 16 Oct 2026 | None identified |
| Hong Kong | Stablecoins Ordinance | In force; first licences Apr 2026 | None identified |
| United Arab Emirates | CBUAE Payment Token Services | In force | None identified |
| Japan | Payment Services Act | In force since June 2023 | None identified |
| Switzerland | FINMA guidance | Supervisory guidance | None identified |
United States: the GENIUS Act
Signed on 18 July 2025, the Act takes effect on the earlier of 18 January 2027 or 120 days after final rules; the OCC proposed its rule on 25 February 2026. Only permitted issuers may issue. Reserves must be held one-for-one in cash, insured deposits, Treasury bills of 93 days or less and similar assets. Issuers may not pay interest, must publish monthly reserve reports, and must be able to freeze, seize or burn tokens under a lawful order (Section 4(a)(6)(B)). The separate CLARITY market-structure bill failed a Senate cloture vote, 49 to 50, on 15 September 2026.
European Union: MiCA
E-money token issuers must be credit institutions or e-money institutions. Holders can redeem at par at any time without a fee (Article 49), and no interest may be paid (Article 50). At least 30% of reserve funds sit with credit institutions. Non-euro tokens used for payments above about one million transactions or EUR 200 million a day must be brought back under that threshold.
United Kingdom: the FCA regime
The FCA published final crypto rules on 30 June 2026, with the regime starting on 25 October 2027. Issuing a qualifying stablecoin in the UK will need FCA authorisation; systemic coins fall to the Bank of England.
Singapore: the MAS framework
MAS finalised its single-currency stablecoin framework in August 2023: full reserves in cash and short-dated sovereign debt, redemption at par within five business days, and base capital of at least S$1 million or half of annual operating costs. A consultation on implementing legislation ran from 1 September to 16 October 2026.
Hong Kong: the Stablecoins Ordinance
In force since 1 August 2025. Issuers need an HKMA licence and at least HK$25 million in paid-up capital, may not pay interest, and are expected to process redemptions within one business day. The HKMA granted the first licences on 10 April 2026.
United Arab Emirates: CBUAE payment tokens
Dirham payment tokens must be fully reserved in cash, held in escrow at a UAE-licensed bank outside the issuer's group. Foreign issuers register with the central bank, and algorithmic stablecoins are prohibited.
Japan: the Payment Services Act
Since June 2023 only banks, trust companies and registered funds-transfer providers may issue stablecoins, and intermediaries need their own registration.
Switzerland: FINMA guidance
FINMA expects issuers without a banking licence to secure a default guarantee from a Swiss bank. We have not yet confirmed the current guidance text, and treat it as unverified in our dataset.
For banks everywhere: the Basel standard
The Basel Committee's cryptoasset standard has applied since 1 January 2026, with an expedited review announced on 25 February 2026. A stablecoin can qualify for Group 1b only if it passes the redemption-risk test and its issuer is supervised. Otherwise it falls to Group 2, where holdings should stay below 1% of Tier 1 capital and must not exceed 2%. Unhedged Group 2b exposures carry a 1250% risk weight.
What it means for builders
- Design for the strictest market you will sell into. A US issuer needs freeze and seize controls in the contract; most other regimes leave that to practice.
- Yield cannot come from the stablecoin itself in the US, EU or Hong Kong. Products that pay a return sit outside the payment-token rules.
- Bank demand depends on Basel classification as much as on local law.
Every obligation above is in our regulatory dataset with its source. The Lab's Forge turns a choice of jurisdictions into the contract controls and the checklist they require.
Research and technical reference: not legal advice and not investment advice. Figures carry their source and date; regulatory summaries should be confirmed with counsel in the relevant jurisdiction.
- GENIUS Act enacted: overview, Greenberg Traurig (Jul 2025)
- GENIUS Act §4(a)(6)(B) lawful-order capability, Federal Register (Apr 2026)
- OCC proposed rule under the GENIUS Act, Morrison Foerster (Mar 2026)
- CLARITY Act fails Senate cloture vote, CoinDesk (15 Sep 2026)
- MiCA Article 49: redemption at par, ESMA
- MiCA Article 50: no interest on e-money tokens, ESMA
- Regulation of e-money tokens under MiCA, Lindemann Law
- FCA sets crypto rules, FCA press release (Jun 2026)
- MAS finalises stablecoin framework, Morgan Lewis (Aug 2023)
- MAS consults on implementing the stablecoin regime, Reed Smith (2026)
- Hong Kong stablecoin licensing now in effect, Davis Polk
- HKMA grants first stablecoin issuer licences (10 Apr 2026)
- CBUAE Payment Token Services Regulation: 10 things to know, CMS
- Stablecoins under Japan's amended Payment Services Act, IFLR
- BCBS cryptoasset standard amendments, BIS d579 (Jul 2024)
- BCBS Group 2 exposure limit, BIS d545
- BCBS announces expedited review of the cryptoasset standard (25 Feb 2026)
- UnyKorn regulatory dataset (/api/regulation)