Global Trends in Stablecoin Regulatory Policies

Stablecoins are becoming a hot topic that permeates daily life. From trending on social media to the traditional financial sector, the influence of stablecoins continues to expand. Meanwhile, the attitudes of global policymakers have also undergone significant changes. Over the past year, multiple countries have shifted from cautious observation to active acceptance: Hong Kong is about to implement the Stablecoin Regulation, the European Union has officially launched the MiCA legislation, and the United States has passed the Genius Act. Stablecoins are quietly changing the landscape of the global monetary system.

This article systematically reviews the latest developments in stablecoin regulation in major countries and regions around the world, analyzing the deep logic and strategic significance of this financial transformation.

Evolution of Stablecoin Policies in the Twelve Major Global Markets

USA: State federation division, competitive layout

Policy Progress Speed: ★★★★

The development of stablecoins in the United States presents a "federal + state" dual-track parallel pattern. At the federal level, there is an acceleration of a unified regulatory framework, while at the state level, specific systems are being tested and implemented first.

At the state level, many regions have launched regulatory frameworks:

• Wyoming has passed the Wyoming Stablecoin Act, establishing a special committee and planning to issue a state-backed stablecoin WYST.
• New York State requires stablecoin issuers to obtain a BitLicense or trust company license.
• California has passed the "Digital Financial Assets Act," establishing a comprehensive licensing system that includes stablecoins.

At the federal level, the legislative process is accelerating:

• The "GENIUS Act" has recently come into effect, requiring issuers to disclose reserve composition, undergo audits, and more.
• The "STABLE Act" has passed the House review, with content similar to the "GENIUS Act."

China: Hong Kong takes the lead, the mainland observes

Policy Progress Speed: Hong Kong ★★★★ | Mainland ★

China has formed a regulatory linkage pattern for stablecoins with "Hong Kong taking the lead and the mainland observing."

The Hong Kong "Stablecoin Regulation" will take effect soon. Approximately 50-60 companies have expressed their intention to apply, mainly payment institutions and large internet platforms. The industry expects that only 3-4 licenses will be issued in the first batch, with a high threshold. Initially, stablecoins will mainly be pegged to the Hong Kong dollar and the US dollar.

On the mainland side, a cautious attitude has been maintained for a long time, but recently many places have released signals of concern:

• Wuxi proposes to explore "stablecoin empowering foreign trade development"
• Jinan releases articles related to stablecoin
• The Shanghai State-owned Assets Supervision and Administration Commission conducts studies on the development trends of stablecoins.
• The China Industrial Internet Research Institute hosted a stablecoin seminar.

South Korea: Attitude Shift, Bank Alliance Layout

Policy progress speed: ★★★

South Korea is shifting from "watching" to "entering the market". The new president has pledged to support the development of the Korean won stablecoin, and the ruling party has proposed the "Basic Digital Asset Act" to allow local companies to issue stablecoins.

Currently, the eight major banks are preparing to establish a joint venture, planning to jointly issue a Korean won stablecoin. The participating institutions include local banks such as Kookmin Bank and Shinhan Bank, as well as the Korean branches of foreign banks like Citibank and Standard Chartered. If the project is approved, it is expected to go live by the end of this year or early next year.

However, there is still uncertainty in regulation. The market is showing signs of a stablecoin bubble, with significant fluctuations in the stock prices of related listed companies.

Thailand: Policy Opens Up, Cautiously Testing the Waters

Policy progress speed: ★★★

Thailand's stablecoin policy is gradually shifting from vigilance to cautious piloting. In 2021, the central bank launched regulatory exploration for stablecoins, classifying the Thai baht stablecoin as "electronic money" under regulation.

Since 2024, the pilot scope has been rapidly expanding:

• The Ministry of Finance is considering issuing a government bond-supported stablecoin.
• Regulatory authorities approve USDT and USDC to enter regulated exchanges
• Launching the "national-level crypto sandbox", allowing foreign tourists to exchange stablecoins for Thai Baht for travel consumption.

EU: Unified regulation, cautious support

Policy Progress Speed: ★★★★★

The EU adopts a "cautious support" attitude towards stablecoins: affirming their potential while remaining vigilant about risks to financial stability and others.

The "Crypto Asset Market Regulation" ( MiCA ) has officially come into effect, providing a unified regulatory framework for 27 EU member states and 3 countries in the European Economic Area. MiCA sets high thresholds for stablecoins:

• Issuers must obtain authorization from the regulatory authorities of member states and establish a legal entity in the EU.
• Stablecoins that meet the "importance" criteria are regulated uniformly by the European Banking Authority.
• The daily trading volume of non-euro denominated stablecoins is capped, and exceeding the limit requires suspension of issuance and rectification.

Currently, the EU has issued MiCA licenses to 53 crypto companies, including 14 stablecoin issuers.

Singapore: early start, high standards

Policy Progress Speed: ★★★★★

Singapore's regulatory framework for stablecoins started relatively early. In 2019, the Payment Services Act was introduced, defining payment service providers. In 2023, the Monetary Authority of Singapore (MAS) officially released the Stablecoin Regulatory Framework as a supplementary provision to the Payment Services Act.

MAS has set a high entry threshold, including:

• The capital shall not be less than 50% of the annual operating expenses or 1 million Singapore dollars.
• The issuer shall not engage in trading, asset management, or other businesses.
• Liquid assets meet normal withdrawal needs
• Reserve assets are limited to cash, short-term bonds, and other low-risk assets.

Currently, multiple institutions have applied for stablecoin issuance qualifications, with StraitsX and Paxos seen as leading compliant demonstration cases.

UAE: Actively promoting, dual-track approach

Policy Progress Speed:★★★★★

The UAE has an open and supportive attitude towards stablecoins. In 2024, the central bank will issue the "Payment Token Services Regulation", clarifying the definition and regulatory framework for stablecoins.

As a federal state, the UAE has formed a unique "dual-track" regulatory system: the central bank is responsible for regulation at the federal level, while the Dubai International Financial Centre and Abu Dhabi Global Market enjoy independent regulatory authority as financial free zones.

Compared to other regions, the UAE has a relatively loose definition of stablecoin, but still sets boundaries:

• Prohibit algorithmic stablecoins and privacy tokens
• Interest linked to the holding period of the coin is not allowed.

By the end of 2024, AE Coin was approved as the first regulated Dirham stablecoin. In 2025, several financial institutions jointly announced the launch of a new type of Dirham stablecoin.

Japan: Regulation Leads, Development Awaits

Policy Progress Speed: ★★★★

Japan's regulation of stablecoins is at the forefront globally, mainly achieved through the Payment Services Act (PSA). The revised version of the PSA came into effect in 2023, clarifying the definitions of stablecoins, issuing entities, and transaction licensing requirements. The issuing entities are limited to three types: banks, trust companies, and money transfer service providers.

In 2025, the Japan Financial Services Agency will promote a new round of PSA revisions to optimize the stablecoin issuance mechanism: allowing up to 50% of reserve assets to be used for low-risk tool investments, and adding a specialized registration category for cryptocurrency intermediaries.

Russia: Mainly exploratory, still limited external use

Policy Progress Speed:★★

Russia's attitude towards stablecoins has shifted from initial opposition to limited support, mainly due to the demand for cross-border settlement. In 2024, the Federal Assembly passed a bill allowing companies approved by the central bank to use crypto assets for international settlements, but they are still prohibited as a means of payment domestically.

In 2025, the central bank proposed to allow specific high-net-worth individuals and enterprises to invest in crypto assets during a three-year pilot period. Treasury officials publicly called for consideration of launching a sovereign stablecoin.

UK: Regulatory progress underway

Policy Progress Speed: ★★

The UK's stablecoin policy is in a transition period from framework design to legislative implementation. Based on the "Financial Services and Markets Bill 2023", supplemented by secondary regulations established by regulatory agencies. This bill for the first time includes "digital settlement assets" within the scope of regulated financial activities.

By the end of 2023, the financial regulatory authority announced the regulatory requirements for stablecoin issuance or custody companies. In 2025, the government will release a draft legislation on cryptocurrency, intending to add regulated activities.

Despite the continuous advancement of regulations, the central bank governor holds a more conservative attitude towards stablecoins, believing that they may undermine public trust in the national currency.

Canada: Legal ambiguity, regulation taking shape

Policy progress speed: ★★

Canada's policies are relatively conservative, and the local stablecoin market is developing slowly. At the end of 2022, securities regulators tightened policies, bringing stablecoins under the regulation of "securities and/or derivatives."

Since the beginning of 2023, regulatory authorities have issued a series of documents proposing a regulatory framework for "fiat-backed stablecoins." Issuers are required to register as securities issuers and submit a prospectus or sign a commitment letter.

Recently, banking regulators have stated that they are ready to regulate stablecoins, and relevant frameworks are being developed.

Brazil: Strict Control Guidance

Policy progress speed:★

Over 90% of cryptocurrency transactions in Brazil involve stablecoins, mainly used for cross-border payments, but it raises compliance concerns. The central bank believes that stablecoin transactions may be used for tax evasion or money laundering.

By the end of 2024, the Central Bank of Brazil proposed a new regulatory draft to include stablecoins under foreign exchange regulation and prohibit transfers to wallets controlled by non-domestic entities. The overall regulatory direction is clear: prioritizing the suppression of high-risk trading scenarios under the premise of strong control.

Despite increasing regulation, some traditional banks are beginning to explore compliant development paths. Brazil's largest bank, Itau Unibanco, plans to launch a stablecoin pegged to the real and is currently awaiting the release of a regulatory framework.