Stablecoin Regulation by Country: 2026 Compliance Guide

The past few years have seen a seismic shift in stablecoin oversight. As of January 2026, stablecoins have grown into a core settlement layer, with a combined market cap exceeding $300 billion (USD) and on-chain monthly transfer volumes frequently reaching hundreds of billions across major networks. 

What began as an unregulated niche of the digital‑asset market has moved rapidly toward formal recognition and stablecoin compliance 2026 frameworks. Major economies now regulate fiat‑backed tokens, differentiate between asset‑referenced and e‑money tokens, and require capital, reserve and disclosure obligations.

This guide explains where cryptocurrency regulation stands, and what it means for companies planning cross‑border payment operations in 2026 and beyond. 

Why stablecoin regulation matters in 2026?

Global regulators are moving swiftly from ambiguity to formal oversight. By 2026, most economies will impose licensing, reserve and redemption obligations on issuers, closing the “unregulated” era. This shift has significant consequences for payment companies.

Shift from regulatory uncertainty to clarity.

The Markets in Crypto-Assets Regulation (MiCA), adopted in 2023, distinguishes asset-referenced and e-money tokens regulations and requires issuers to publish white papers, obtain authorisation and hold segregated reserves. 

Singapore’s MAS framework adds minimum capital, strict reserve rules and five-day redemption. 

The U.S. GENIUS Act (2025) creates a federal licence for payment stablecoin issuers with defined reserve standards. 

Hong Kong, the UAE and Australia have introduced stablecoin licensing requirements with full-reserve backing. These measures bring clarity but increase compliance obligations.

Key shifts:

• MiCA classification rules and mandatory issuer authorisation
• Singapore capital, reserve and redemption requirements
• U.S. federal licensing under the GENIUS Act
• Full-reserve and licensing regimes in Hong Kong, the UAE and Australia
• Greater global alignment on audited reserves and consumer protection

Impact on payment infrastructure providers

For fintechs building cross‑border payment rails, regulation lowers legal risk but raises operational complexity. Issuers now need licences in each jurisdiction, must maintain separate reserve accounts for each currency, and implement global AML controls. 

Compliance becomes a core product feature, not an afterthought. Companies must design systems that align with overlapping but sometimes divergent stablecoin reserve requirements and reporting schedules.

Consequences of non‑compliance

Penalties for violations are severe. Issuing fiat‑referenced stablecoins in Hong Kong without a licence after 1 August 2025 constitutes a criminal offence. Australia’s draft bill threatens up to five years’ imprisonment for operating an unlicensed tokenised stored‑value facility. The UAE’s rulebook requires redemption within one working day and monthly audits; failure to meet these obligations could lead to licence suspension. Such sanctions highlight the importance of proactive compliance.

Why do fintech companies need multi‑jurisdiction compliance?

Most fintech operators serve clients across borders. Because stablecoin regulation remains jurisdiction‑specific, companies must assess where their customers reside, where issuance occurs, and which regulators assert jurisdiction. Licences may be required even when operations are remote, as Japan and Texas apply rules based on customer location. A coordinated multi‑jurisdiction strategy is therefore essential.

European Union: MiCA framework

The EU’s MiCA is the world’s most comprehensive stablecoin regulatory framework. It introduces new categories of tokens, authorisation requirements and disclosure obligations. Firms operating in the EU must understand these rules to plan issuance and servicing.

Overview of markets in digital assets regulation

MiCA classifies stablecoins into asset-referenced tokens (ARTs), backed by multiple currencies or commodities, and e-money tokens (EMTs), which are pegged to a single fiat currency. Only EMTs may be marketed as “electronic money” and give holders a redemption right. Both categories require authorisation from a national competent authority and fall under European Banking Authority supervision. Issuers must also publish a white paper explaining the stabilisation mechanism and detailing reserve assets.

Key points:

• ARTs reference a basket of assets; EMTs reference one fiat currency
• Only EMTs may be marketed as electronic money with a redemption right
• Issuers of both token types require regulatory authorisation
• EBA oversees governance, disclosure and ongoing supervision

Asset‑referenced tokens vs e‑money tokens

ART issuers face stricter governance requirements because their backing may be more complex. They must maintain a reserve of liquid, low‑risk assets equal to the token’s value and set up robust risk management and governance frameworks. EMT issuers must be electronic money institutions or credit institutions and hold segregated reserve assets equal to the outstanding token value. Both categories require periodic audits and public disclosures.

Reserve requirements and audit obligations

MiCA mandates 100 per cent reserve backing with segregated, low‑risk assets (e.g., cash, short‑term government debt). Issuers must publish the composition of reserves and results of audits at regular intervals. Senior management must be competent and of good repute. Firms must implement internal control and risk‑management systems to ensure the integrity of reserve maintenance and redemption processes.

Licensing pathways for payment providers

EMT issuers must obtain an electronic money institution licence or operate as a credit institution under existing EU law. ART issuers require a specific authorisation under MiCA. Service providers such as wallet providers and exchanges must register as CASPs (crypto‑asset service providers) and meet prudential requirements. Importantly, MiCA introduces a passporting regime: once licensed in one member state, an issuer may operate across the EU, but must still notify host states.

Timelines and implementation phases

The stablecoin provisions of MiCA stablecoin rules came into force in June 2023. CASPs could apply for licenses starting January 2025 (varies by jurisdiction) and may continue operating under national laws during a transitional period of up to 18 months (until July 1, 2026, at the latest), though many EU countries have shorter transition periods. After the transition period ends in their jurisdiction, full MiCA compliance is mandatory. Firms launching stablecoins in the EU should therefore secure e‑money licences, implement reserve management systems and prepare for public disclosures ahead of mid‑2026.

What does this mean for companies operating in the EU?

To issue or distribute stablecoins in the EU after July 2026, companies must: 

(1) obtain the appropriate licence (e‑money institution, credit institution or ART issuer); 

(2) establish segregated reserve accounts with liquid assets; 

(3) publish white papers and regular reserve reports; and 

(4) build governance structures that satisfy the European Banking Authority’s supervisory expectations. 

Failure to meet these requirements can lead to fines and suspension of operations.

United States: State‑by‑state approach

U.S. regulation remains a patchwork, but the 2025 GENIUS Act marks the first federal framework for payment stablecoins. State laws continue to play a significant role, particularly where federal certification is not sought or where additional consumer protections apply.

Federal landscape: GENIUS Act

Under US stablecoin regulation, the GENIUS Act (18 July 2025) defines payment stablecoins as tokens redeemable 1:1 for U.S. dollars and creates two issuer types: federal OCC-supervised issuers and state-certified issuers. Issuers must hold safe, liquid reserves and publish monthly audited disclosures. State issuers are capped at a $10 billion (USD) market cap, and activities beyond issuance, redemption and settlement require separate licences.

Key points:

• Two issuer categories: federal OCC-supervised and state-certified
• Mandatory 1:1 reserve backing and monthly audits
• $10 billion (USD) cap for state issuers
• Only core issuance and settlement are allowed without extra licences

Money transmitter licence requirements and key states

Even with the GENIUS Act, state laws remain relevant. New York requires stablecoins under its supervision to be fully backed by cash or short‑term Treasuries, segregated from issuer assets and subject to monthly independent CPA attestations. Issuers must honour redemption at par within two business days. 

Texas treats fiat‑referenced stablecoins as “money” and requires a money transmitter licence to receive or transmit them. Transactions solely in decentralised cryptocurrencies do not trigger licensing. Wyoming offers special purpose depository institutions (SPDIs) and has launched a state‑backed Frontier (FRNT) stablecoin. Operators must therefore evaluate the laws of each state where they issue or redeem tokens.

Proposed federal frameworks in discussion

Legislators continue to debate proposals such as the Stablecoin Transparency Act, which could impose deposit insurance or other requirements. Companies should monitor these developments, although the GENIUS Act sets the current baseline: 1:1 reserve backing, monthly audits and federal or state certification.

United Kingdom: Post‑Brexit approach

The UK is creating its own regime for stablecoins. While final rules are still pending, consultation papers provide insight into likely requirements. Companies should prepare for reserves, capital buffers and holding limits.

FCA guidance on stablecoins as payment instruments

The Bank of England’s November 2025 consultation recommends 100 percent reserves for systemic sterling stablecoins, split between BoE deposits and short-term UK government debt. Issuers would follow CPMI-IOSCO standards and meet capital, liquidity and operational-resilience requirements. Proposed holding limits are £20,000 per individual and £10 million per business.

Key points:

• Full-reserve model using BoE deposits and short-term UK debt
• CPMI-IOSCO governance and resilience standards
• Holding limits: £20k per person, £10m per business

Differences from MiCA

Unlike MiCA stablecoin rules, which apply across the EU and mandate a single licence, the UK’s framework is likely to be standalone and more flexible in reserve composition (allowing government debt holdings). The UK may also emphasise systemic risk management and require holding limits that MiCA does not. However, both regimes demand full reserve backing and robust governance.

Authorisation requirements and timeline

Stablecoin issuance and custody will fall under the Financial Services and Markets Act, with the Financial Conduct Authority (FCA) overseeing authorisations. Existing e‑money institutions may apply, but they must meet higher standards than those for prepaid cards. Final rules and a Code of Practice are expected in 2026, and issuers should prepare for reserve segregation, capital requirements and reporting.

Singapore: MAS payment token framework

Singapore was among the first jurisdictions to announce a dedicated framework for single-currency stablecoins. In August 2023, MAS finalized the policy features of its stablecoin regulatory framework. As of December 2025, MAS is drafting the legislative bill, which will require parliamentary approval before the framework takes legal effect.

Digital Payment Token services licensing

Issuers and intermediaries of single‑currency stablecoins pegged to the Singapore dollar (SGD) or G10 currencies must obtain a Digital Payment Token services licence under the Payment Services Act. Multi‑currency or algorithmic stablecoins are excluded. Licences cover issuance, custody and exchange services.

Stablecoin‑specific considerations

To display the label “MAS‑regulated stablecoin,” issuers must meet stringent requirements. Only single‑currency stablecoins pegged to SGD or G10 currencies qualify; tokens referencing other currencies cannot claim compliance. Issuers must remain fully redeemable and disclose stabilisation mechanisms. Holders who fail to comply with redemption obligations lose their regulated status.

Reserve and audit requirements

Issuers must maintain reserve assets equal to the par value of outstanding tokens. These assets must be high‑quality, liquid instruments and are subject to valuation, custody and audit rules. Issuers must also hold minimum base capital and liquid assets and provide redemption at par within five business days. Public disclosures must explain the stabilising mechanism and publish audit results.

Why Singapore is attractive for stablecoin issuers?

Singapore offers regulatory certainty, clear stablecoin licensing requirements and a supportive fintech environment. Its rules are stringent yet transparent, making it a hub for global issuers seeking a credible regulatory base. The balance between consumer protection and innovation attracts firms to set up operations or partner with licensed entities in the city‑state.

Other key jurisdictions

Stablecoin regulation extends beyond the big three. Japan, Hong Kong, the UAE and Australia each have distinct frameworks that must be considered by international operators.

Japan: Payment Services Act

Japan amended its Payment Services Act in June 2023 to regulate stablecoins. It distinguishes between digital money‑type stablecoins, electronic payment instruments pegged to fiat currency, and crypto‑asset‑type stablecoins. 

Only banks, fund transfer service providers and trust banks may issue digital money‑type stablecoins. Banks treat tokens as deposits covered by deposit insurance; fund transfer providers must secure obligations via cash deposits or guarantees; trust banks must hold all assets in segregated deposits. 

Hong Kong: VASP licensing

From 1 August 2025, issuing fiat‑referenced stablecoins in Hong Kong becomes a regulated activity requiring a licence. Licensees must ensure the market value of reserve assets is at least equal to outstanding tokens and hold only high‑quality, liquid assets, cash, and deposits with residual maturity ≤3 months, high‑quality debt maturing in <1 year, reverse repos or dedicated funds, in segregated accounts. 

They must over‑collateralise where appropriate and reconcile reserves regularly. Redemption at par must occur within one business day, and licensees must perform customer due diligence (CDD) and implement group‑wide AML/CFT programmes.

UAE: VARA framework (Dubai)

The Virtual Assets Regulatory Authority (VARA) issued its FRVA rulebook in May 2025. Virtual asset service providers must obtain approval for each fiat-referenced token, which may circulate only within the virtual asset ecosystem and cannot be used for general payments or reference sanctioned currencies. 

Reserves must fully back supply using cash, central-bank balances or short-term sovereign debt (≤90 days) held in segregated accounts. Issuers must publish monthly disclosures, commission independent audits with senior management attestations and honor par-value redemption within one working day. VASPs must also maintain a minimum capital of AED 1.5 million plus 2% of outstanding supply.

Australia: proposed framework

Australia’s draft legislation, released in November 2025, treats stablecoins as tokenised stored‑value facilities (SVFs). Issuers and facilitators must obtain an Australian Financial Services Licence and comply with general financial services obligations. Tokenised SVF providers must publish material changes affecting reserves and provide monthly statements of reserve composition and outstanding liabilities.

The law proposes civil and criminal penalties, including up to five years’ imprisonment for non‑compliance. Final legislation is expected in 2026; issuers should prepare to secure a licence and set up reporting mechanisms.

Common compliance requirements across jurisdictions

Despite differences in legal frameworks, most regimes share core principles. Understanding these commonalities helps firms design a unified compliance architecture that satisfies multiple regulators.

How does Due support compliant stablecoin payments?

Due delivers a non‑custodial, multi‑jurisdiction payment infrastructure that connects traditional banking rails and stablecoin networks. Its platform helps payment companies achieve cross‑border stablecoin compliance through built‑in features:

• Multi‑jurisdiction support. Due integrates SWIFT, SEPA, ACH and major stablecoin networks, enabling operations across 80+ countries. The platform’s configuration engine adapts to local licensing regimes and handles reserve segregation and reporting.
• Built‑in compliance. Automated AML/KYC modules, sanction screening and travel‑rule‑compliant messaging meet global due diligence standards. Reconciliation tools monitor reserve assets and produce monthly reports.
• Non‑custodial design. Due to orchestrated transfers without taking custody of funds. This reduces licensing burdens while ensuring secure settlement between banks, issuers and digital wallets.
• Cross‑border orchestration. Unified APIs manage foreign exchange, fee calculation, on‑chain settlement and fiat off‑ramps, accelerating time to market.

By embedding these capabilities, Due enables fintech operators to focus on product innovation while relying on a platform designed around regulatory best practices

If you’re evaluating stablecoin settlement or expanding into new jurisdictions, see how Due’s infrastructure can help you stay compliant. Book a demo to learn more.