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The disruptive impact of stablecoins continues to grow.
From trending topics on TikTok to traditional finance influencers pivoting their content, and even inquiries from neighbors and relatives, stablecoins have seemingly become a buzzword permeating daily life.
Simultaneously, a critical shift is unfolding in global policymaking. Over the past year, many countries have transitioned from cautious观望 to active acceptance: Hong Kong’s Stablecoin Ordinance is set to take effect, the EU’s MiCA framework has been implemented, and the U.S. has passed the GENIUS Act. Stablecoins are quietly reshaping the foundation of the global monetary system.
This article systematically examines the latest regulatory developments across countries, decoding the underlying logic and strategic significance of this financial revolution.
Breaking Boundaries: A Comparative Analysis of Stablecoin Regulations Across 12 Countries
Regulatory Progress Speed: ★★★★
Stablecoin development in the U.S. follows a "federal + state" dual-track approach. While the federal government accelerates unified legislation, individual states are pioneering localized frameworks.
State-Level Initiatives:
Wyoming: Passed the Wyoming Stablecoin Act in 2023, establishing the Wyoming Stablecoin Commission and planning to launch the state-backed WYST stablecoin by August 20, 2025.
New York: Since 2018, the NYDFS has required stablecoin issuers to obtain a BitLicense or trust charter, enforcing strict compliance.
California: Enacted the Digital Financial Assets Law (DFAL) in 2023, creating a comprehensive licensing regime for stablecoin issuers, effective July 2026.
Federal-Level Advancements:
The GENIUS Act was signed into law by President Trump on July 19, 2025. Key provisions include:
Banning yield-bearing stablecoins.
Mandating monthly reserve disclosures and audits.
Holding CEOs/CFOs accountable for data accuracy.
Allowing issuers to choose federal or state oversight (small issuers under $10B may opt for state-only regulation).
The STABLE Act, proposed in March 2025 and now under Senate review, largely mirrors the GENIUS Act.
Regulatory Progress Speed: Hong Kong ★★★★ | Mainland ★
China’s approach features a "Hong Kong-first, mainland-cautious" dynamic. Hong Kong is establishing a mature regulatory regime to attract businesses, while the mainland remains guarded but curious.
Hong Kong:
The Stablecoin Ordinance takes effect on August 1, 2025.
50–60 companies (half payment firms, half tech giants like JD.com, Standard Chartered, and Ant Group) have expressed interest in licensing. Only 3–4 licenses are expected initially, with a high bar for entry.
Initial stablecoins will likely be pegged to HKD or USD, with licensing possibly invitation-only.
Mainland:
Historically restrictive, but recent signals suggest growing interest:
Wuxi (July 7): Proposed exploring stablecoins for foreign trade.
Jinan (July 9): Published a state-media article on stablecoins.
Shanghai (July 10): Government officials studied crypto/stablecoin trends.
National (July 18): Hosted an industrial seminar on stablecoins.
Regulatory Progress Speed: ★★★
South Korea is transitioning from观望 to action. On June 10, 2025, the ruling party proposed the Digital Asset Basic Act, allowing local firms with capital over $368K to issue stablecoins.
Eight major banks (e.g., KB, Shinhan, Woori) are forming a consortium to launch a KRW-pegged stablecoin, potentially by late 2025. However, regulatory uncertainty persists, with Four Pillars’ 100y.eth noting a "stablecoin bubble" amid daily news of trademark filings and stock surges.
Regulatory Progress Speed: ★★★
Thailand has moved from skepticism to controlled testing:
2021: Baht-pegged stablecoins classified as "e-money," requiring central bank approval.
2024: Launched a regulatory sandbox.
2025: Expanded pilots, including a potential 10B THB bond-backed stablecoin and USDT/USDC approvals for tourism payments.
Regulatory Progress Speed: ★★★★★
The EU’s Markets in Crypto-Assets (MiCA) framework, effective June 2024 (stablecoin rules by December 2024), sets high standards:
Issuers need authorization from national regulators (e.g., Germany’s BaFin).
Non-euro stablecoins face daily transaction caps (1M txs or €200M).
53 licenses granted so far, including 14 to stablecoin issuers.
Regulatory Progress Speed: ★★★★★
Since 2019’s Payment Services Act, Singapore has refined its rules:
2023’s Stablecoin Framework mandates:
SGD/G10-pegged stablecoins only.
Minimum S$1M capital.
Reserve limits (cash/short-term bonds).
StraitsX (XSGD) and Paxos are early adopters.
Regulatory Progress Speed: ★★★★★
The UAE’s 2024 Payment Token Regulations allow federal and free-zone (DIFC/ADGM) experimentation:
Bans algorithmic/private stablecoins.
No interest payments.
AE Coin (2024) and an ADQ/IHC-backed stablecoin (2025) are milestones.
Regulatory Progress Speed: ★★★★
Japan’s 2023 Payment Services Act amendments restrict issuers to banks/trusts. 2025 reforms allow 50% reserves in low-risk assets (e.g., T-bills).
Regulatory Progress Speed: ★★
2024 laws legalize crypto mining and allow approved firms to use stablecoins for cross-border trade. Domestic payments remain banned, but a sovereign stablecoin is under discussion.
Regulatory Progress Speed: ★★
The Financial Services and Markets Act 2023 brings stablecoins under FCA oversight, but BoE Governor Andrew Bailey warns of risks to monetary sovereignty.
Regulatory Progress Speed: ★★
Stablecoins are treated as securities, requiring prospectuses or CSA exemptions. A formal framework is pending.
Regulatory Progress Speed: ★
With 90% of crypto trades involving stablecoins (mostly for cross-border payments), Brazil’s 2024 draft rules aim to curb tax evasion by regulating them as foreign exchange. Itaú Unibanco plans a BRL-pegged stablecoin post-regulation.
Conclusion:
From Hong Kong’s licensing race to the EU’s MiCA and the U.S.’s dual-track system, stablecoin regulations reflect each jurisdiction’s balancing act between innovation and risk. As this space evolves, one truth is clear: stablecoins are no longer niche—they’re rewriting global finance.
Image Credit: ChainCatcher | Disclaimer: Views are the author’s alone.
Tags: Stablecoins | Regulation | MiCA | GENIUS Act | DeFi | Central Banks
Related Reading:
Follow ChainCatcher for real-time updates.
WeChat | Telegram | Twitter @ChainCatcher
The disruptive impact of stablecoins continues to grow.
From trending topics on TikTok to traditional finance influencers pivoting their content, and even inquiries from neighbors and relatives, stablecoins have seemingly become a buzzword permeating daily life.
Simultaneously, a critical shift is unfolding in global policymaking. Over the past year, many countries have transitioned from cautious观望 to active acceptance: Hong Kong’s Stablecoin Ordinance is set to take effect, the EU’s MiCA framework has been implemented, and the U.S. has passed the GENIUS Act. Stablecoins are quietly reshaping the foundation of the global monetary system.
This article systematically examines the latest regulatory developments across countries, decoding the underlying logic and strategic significance of this financial revolution.
Breaking Boundaries: A Comparative Analysis of Stablecoin Regulations Across 12 Countries
Regulatory Progress Speed: ★★★★
Stablecoin development in the U.S. follows a "federal + state" dual-track approach. While the federal government accelerates unified legislation, individual states are pioneering localized frameworks.
State-Level Initiatives:
Wyoming: Passed the Wyoming Stablecoin Act in 2023, establishing the Wyoming Stablecoin Commission and planning to launch the state-backed WYST stablecoin by August 20, 2025.
New York: Since 2018, the NYDFS has required stablecoin issuers to obtain a BitLicense or trust charter, enforcing strict compliance.
California: Enacted the Digital Financial Assets Law (DFAL) in 2023, creating a comprehensive licensing regime for stablecoin issuers, effective July 2026.
Federal-Level Advancements:
The GENIUS Act was signed into law by President Trump on July 19, 2025. Key provisions include:
Banning yield-bearing stablecoins.
Mandating monthly reserve disclosures and audits.
Holding CEOs/CFOs accountable for data accuracy.
Allowing issuers to choose federal or state oversight (small issuers under $10B may opt for state-only regulation).
The STABLE Act, proposed in March 2025 and now under Senate review, largely mirrors the GENIUS Act.
Regulatory Progress Speed: Hong Kong ★★★★ | Mainland ★
China’s approach features a "Hong Kong-first, mainland-cautious" dynamic. Hong Kong is establishing a mature regulatory regime to attract businesses, while the mainland remains guarded but curious.
Hong Kong:
The Stablecoin Ordinance takes effect on August 1, 2025.
50–60 companies (half payment firms, half tech giants like JD.com, Standard Chartered, and Ant Group) have expressed interest in licensing. Only 3–4 licenses are expected initially, with a high bar for entry.
Initial stablecoins will likely be pegged to HKD or USD, with licensing possibly invitation-only.
Mainland:
Historically restrictive, but recent signals suggest growing interest:
Wuxi (July 7): Proposed exploring stablecoins for foreign trade.
Jinan (July 9): Published a state-media article on stablecoins.
Shanghai (July 10): Government officials studied crypto/stablecoin trends.
National (July 18): Hosted an industrial seminar on stablecoins.
Regulatory Progress Speed: ★★★
South Korea is transitioning from观望 to action. On June 10, 2025, the ruling party proposed the Digital Asset Basic Act, allowing local firms with capital over $368K to issue stablecoins.
Eight major banks (e.g., KB, Shinhan, Woori) are forming a consortium to launch a KRW-pegged stablecoin, potentially by late 2025. However, regulatory uncertainty persists, with Four Pillars’ 100y.eth noting a "stablecoin bubble" amid daily news of trademark filings and stock surges.
Regulatory Progress Speed: ★★★
Thailand has moved from skepticism to controlled testing:
2021: Baht-pegged stablecoins classified as "e-money," requiring central bank approval.
2024: Launched a regulatory sandbox.
2025: Expanded pilots, including a potential 10B THB bond-backed stablecoin and USDT/USDC approvals for tourism payments.
Regulatory Progress Speed: ★★★★★
The EU’s Markets in Crypto-Assets (MiCA) framework, effective June 2024 (stablecoin rules by December 2024), sets high standards:
Issuers need authorization from national regulators (e.g., Germany’s BaFin).
Non-euro stablecoins face daily transaction caps (1M txs or €200M).
53 licenses granted so far, including 14 to stablecoin issuers.
Regulatory Progress Speed: ★★★★★
Since 2019’s Payment Services Act, Singapore has refined its rules:
2023’s Stablecoin Framework mandates:
SGD/G10-pegged stablecoins only.
Minimum S$1M capital.
Reserve limits (cash/short-term bonds).
StraitsX (XSGD) and Paxos are early adopters.
Regulatory Progress Speed: ★★★★★
The UAE’s 2024 Payment Token Regulations allow federal and free-zone (DIFC/ADGM) experimentation:
Bans algorithmic/private stablecoins.
No interest payments.
AE Coin (2024) and an ADQ/IHC-backed stablecoin (2025) are milestones.
Regulatory Progress Speed: ★★★★
Japan’s 2023 Payment Services Act amendments restrict issuers to banks/trusts. 2025 reforms allow 50% reserves in low-risk assets (e.g., T-bills).
Regulatory Progress Speed: ★★
2024 laws legalize crypto mining and allow approved firms to use stablecoins for cross-border trade. Domestic payments remain banned, but a sovereign stablecoin is under discussion.
Regulatory Progress Speed: ★★
The Financial Services and Markets Act 2023 brings stablecoins under FCA oversight, but BoE Governor Andrew Bailey warns of risks to monetary sovereignty.
Regulatory Progress Speed: ★★
Stablecoins are treated as securities, requiring prospectuses or CSA exemptions. A formal framework is pending.
Regulatory Progress Speed: ★
With 90% of crypto trades involving stablecoins (mostly for cross-border payments), Brazil’s 2024 draft rules aim to curb tax evasion by regulating them as foreign exchange. Itaú Unibanco plans a BRL-pegged stablecoin post-regulation.
Conclusion:
From Hong Kong’s licensing race to the EU’s MiCA and the U.S.’s dual-track system, stablecoin regulations reflect each jurisdiction’s balancing act between innovation and risk. As this space evolves, one truth is clear: stablecoins are no longer niche—they’re rewriting global finance.
Image Credit: ChainCatcher | Disclaimer: Views are the author’s alone.
Tags: Stablecoins | Regulation | MiCA | GENIUS Act | DeFi | Central Banks
Related Reading:
Follow ChainCatcher for real-time updates.
WeChat | Telegram | Twitter @ChainCatcher
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