Global Stablecoin Frameworks

AUG 2021EUROPE

Switzerland DLT ActFirst comprehensive blockchain legislation creating legal certainty for tokenized assets and DLT-based securities.Introduced DLT securities, segregation rules for crypto custody, and a new license category for DLT trading facilities. Positioned Switzerland as a pioneer in blockchain regulation.

FEB 2023UAE

Dubai VARAWorld's first independent virtual asset regulatory authority with comprehensive licensing framework.Covers 7 virtual asset activities including exchange, custody, and issuance services. Requires AML/CFT compliance, capital reserves, and consumer protection measures across Dubai.

JUN 2023ASIA

Japan PSARestricts stablecoin issuance to licensed banks, money transfer agents, and trust companies only.Amended Payment Services Act creates strict issuer requirements with full reserve backing. Intermediaries must register with FSA and maintain segregated customer assets.

AUG 2023ASIA

Singapore MASMAS-regulated single-currency stablecoin framework requiring 100% reserve backing and daily attestation.Issuers must hold minimum S$1M base capital, maintain reserves in cash or short-term government bonds, and provide redemption at par within 5 business days.

DEC 2023ASIA

Hong Kong FSMRMandatory licensing regime for fiat-referenced stablecoin issuers under the HKMA.Requires full reserve backing with high-quality liquid assets, robust risk management, and regular audits. Non-HKD stablecoins sold to retail must also be licensed.

DEC 2024EUROPE

EU MiCAMarkets in Crypto-Assets Regulation harmonizing rules across all 27 EU member states.Creates ARTs (asset-referenced tokens) and EMTs (e-money tokens) categories. Significant stablecoins face EBA supervision, transaction limits, and enhanced reserve requirements.

JUL 2025AMERICAS

US GENIUS & CLARITYFederal stablecoin payment framework combined with digital asset market structure legislation.GENIUS Act establishes federal/state issuer licensing with 1:1 reserve requirements. CLARITY Act defines commodity vs. security tokens and SEC/CFTC jurisdictional boundaries.

2026-27GLOBAL

Global ImplementationUK, Brazil, South Korea, and Australia finalizing comprehensive stablecoin regulatory frameworks.UK's Financial Services and Markets Bill, Brazil's crypto framework law, Korea's Virtual Asset Act, and Australia's token mapping exercise all expected to be fully implemented.

Global overview