Author: Fairy, ChainCatcher
Editor: TB, ChainCatcher
Original Title: Stablecoin Breaking Boundaries: In-Depth Analysis of Stablecoin Regulatory Policies in 12 Countries
The breaking effect of stablecoins continues to expand.
From frequently appearing topics on TikTok's trending list, to content creation by traditional financial bloggers, and even active inquiries from relatives and neighbors, stablecoins seem to have become a social buzzword permeating daily life.
Meanwhile, the global policy landscape is experiencing a critical turning point. Over the past year, many countries have shifted from cautious observation to acceptance: Hong Kong's Stablecoin Regulation is about to be implemented, the EU's MiCA Act has been officially launched, and the United States has passed the GENIUS Act. Stablecoins are quietly leveraging the foundation of the global monetary system.
This article will systematically review the latest developments in stablecoin regulation across various countries, analyzing the underlying logic and strategic implications of this financial transformation.
A Comprehensive View of Global Stablecoin Regulatory Landscape
Analysis of Stablecoin Policy Evolution in 12 Core Global Markets
United States: State and Federal Divide, Accelerated Layout
Policy Progress Speed: ★★★★
Stablecoin development in the United States presents a dual-track approach of "federal + state" advancement. On one hand, the federal government is accelerating the unification of regulatory frameworks at the legislative level; on the other hand, states are taking the lead in piloting and implementing institutional groundwork.
[The translation continues in the same manner for the rest of the text, maintaining the original structure and translating all non-HTML content to English.]MiCA sets high thresholds for the issuance and operation of stablecoins: issuers must obtain authorization from national regulatory agencies (such as Germany's BaFin, France's AMF) and establish a legal entity in the EU. For stablecoins that meet the "importance" standard (such as those with massive trading volume), they will be uniformly regulated by the European Banking Authority (EBA).
MiCA also stipulates that daily transactions of non-euro-denominated stablecoins in any currency zone shall not exceed 1 million transactions or 200 million euros. Once the limit is exceeded, the issuer must suspend the issuance of the stablecoin and submit a rectification plan within 40 working days.
Currently, the EU has issued MiCA licenses to 53 crypto enterprises, including 14 stablecoin issuers and 39 crypto asset service providers.
Singapore: Early Start, High Standards
Policy Progress Speed: ★★★★★
Singapore is a leader in stablecoin regulation. As early as December 2019, Singapore issued the Payment Services Act, clearly defining and classifying payment service providers. Subsequently, the Monetary Authority of Singapore (MAS) released a draft Stablecoin Regulatory Framework in December 2022 and launched a public consultation, officially launching the final version on August 15, 2023. This regulatory framework specifically applies to single currency stablecoins (SCS) issued in Singapore and pegged to the Singapore dollar (SGD) or G10 currencies, incorporated into the regulatory system as a supplementary clause to the Payment Services Act.
MAS has set high entry barriers, and issuers need to meet the following requirements:
The capital of stablecoin issuers shall not be less than 50% of annual operating expenses or 1 million Singapore dollars;
Stablecoin issuers shall not engage in trading, asset management, pledging, lending, or other businesses, nor directly hold shares in other legal entities;
Liquidity assets shall meet the scale of normal asset withdrawal or be higher than 50% of annual operating expenses.
The reserve assets of stablecoin issuers can only consist of assets with extremely low risk and high liquidity: cash, cash equivalents, and bonds with a remaining maturity of no more than three months.
Currently, multiple institutions have applied to MAS for stablecoin issuance qualifications. Among them, StraitsX (XSGD issuer) and Paxos are considered pioneering compliant examples.
UAE: Actively Promoting, Dual-Track Approach
Policy Progress Speed: ★★★★★
The UAE has shown a supportive and open attitude towards stablecoin policies. In June 2024, the UAE Central Bank issued the Payment Token Services Regulations, clearly defining "payment tokens" (stablecoins) and their regulatory framework.
As a federal state composed of seven emirates, the UAE's regulatory system has a distinctive "dual-track" characteristic: the Central Bank is responsible for federal-level regulation, while the Dubai International Financial Centre (DIFC) and Abu Dhabi Global Market (ADGM) enjoy independent legal systems and regulatory permissions as financial free zones.
Compared to the EU's MiCA or Hong Kong's Stablecoin Ordinance, the UAE's new regulations have a relatively broad definition of stablecoins, but still set certain boundaries:
Prohibit the issuance of algorithmic stablecoins and privacy tokens
Do not allow stablecoins to pay interest or other returns to users linked to holding time
In practical application, the UAE's stablecoin market has already shown initial results. In December 2024, AE Coin was approved by CBUAE, becoming the first fully regulated Dirham stablecoin in the UAE.
In April 2025, ADQ (Abu Dhabi's sovereign wealth fund), IHC corporate group, and First Abu Dhabi Bank, the UAE's largest bank by asset size, jointly announced the launch of a new stablecoin anchored to the Dirham.
Japan: Regulatory Pioneering, Development Pending
Policy Progress Speed: ★★★★
Japan is at the forefront of global stablecoin regulation and has been the first to complete the basic legislative framework. Its regulatory path is mainly achieved through improvements to the Payment Services Act (PSA).
In June 2022, the Japanese parliament passed an amended Payment Services Act, which officially took effect in June 2023. The revised law provides a detailed definition of stablecoins, clarifies issuing entities, and lists the licenses required for stablecoin transactions. It limits stablecoin issuers to three categories: banks, trust companies, and fund transfer service providers.
In March 2025, the Japan Financial Services Agency promoted the Payment Services Act Amendment of 2025, optimizing the stablecoin issuance mechanism: allowing trust-type stablecoins to use up to 50% of reserve assets for specific low-risk tools such as short-term government bonds or time deposits. The law also adds a special registration category for crypto intermediaries, lowering the threshold for over-the-counter trading participation.
Russia: Mainly Exploratory, Still Limiting External Use
Policy Progress Speed: ★★
Russia's attitude towards stablecoins has significantly changed in recent years, from initial caution and even opposition to limited support, mainly due to strategic needs for cross-border settlement and an autonomous financial system under geopolitical pressure.
In 2022, the Russian Central Bank had pushed for a comprehensive ban on cryptocurrencies. However, in July 2024, there was a key policy shift. The Russian Federal Assembly passed two bills, officially legalizing cryptocurrency mining and allowing enterprises approved by the Central Bank to use crypto assets, including stablecoins, for international settlements with foreign partners. However, in the domestic domain, cryptocurrencies are still not permitted as a means of payment.
In March 2025, the Russian Central Bank issued a proposal to allow "specially qualified" high-net-worth individuals and some enterprises to invest in crypto assets during a three-year pilot period, exploring a more transparent and controlled market environment.
Outside the policy context, Ivan Chebeskov, head of the Digital Financial Assets Department of the Ministry of Finance, publicly stated that Russia should consider launching a national sovereign stablecoin to adapt to the evolution of global payment systems.
UK: Regulatory Progress Underway
Policy Progress Speed: ★★
The UK policy is currently at a critical stage of transitioning from framework design to legislative implementation. The related regulatory system is based on the Financial Services and Markets Act 2023, supplemented by secondary legislation and regulatory guidelines from the Financial Conduct Authority (FCA) and the Bank of England (BoE). The act was given royal assent on June 29, 2023, and for the first time incorporated "digital settlement assets" (including stablecoins) into the legal scope of regulated financial activities.
In November 2023, the UK Financial Regulatory Authority published regulatory requirements for companies issuing or custodying fiat-backed stablecoins. The proposed framework will seek to apply several existing regulatory standards currently applicable to many FCA-authorized entities to the stablecoin activity domain.
In April 2025, the UK government released a consultation document on cryptocurrency legislation, planning to add regulated activities, including operating crypto asset trading platforms and stablecoin issuance.
Despite ongoing regulatory progress, the Bank of England's governor has shown a more conservative stance. Governor Andrew Bailey has repeatedly stated publicly that widespread stablecoin adoption could undermine public trust in the national currency and even pose systemic risks to the financial system.
Canada: Vague Regulations, Regulation in Formation
Policy Progress Speed: ★★
Compared to markets like the US and EU, Canada's policy is more conservative, with slow local stablecoin market development.
In December 2022, the FTX collapse triggered global crypto market turbulence, and the Canadian Securities Administrators (CSA) subsequently tightened policies, incorporating stablecoins into the regulatory scope of "securities and/or derivatives".
Since 2023, CSA has successively issued two key documents, SN 21332 and SN 21333, proposing a regulatory framework for "fiat-pegged stablecoins". According to the regulations, stablecoin issuers need to register as securities issuers, submit a prospectus, or sign a commitment letter approved by CSA.
Last month, the Canadian banking regulator stated that they are ready to regulate stablecoins, and the regulatory framework is being developed.
Brazil: Strict Control Direction
Policy Progress Speed: ★
Brazilian Central Bank data shows that over 90% of cryptocurrency transactions in the country involve stablecoins, mainly used for cross-border payments, but this trend has also raised compliance concerns.
Brazilian Central Bank Governor Gabriel Galipolo stated that the central bank initially believed stablecoins were popular because they provided people with a convenient way to hold US dollars. However, after in-depth research, they found that a large number of stablecoin transactions were related to cross-border shopping, and the transaction methods were opaque, potentially being used for tax evasion or money laundering.
Therefore, the Brazilian Central Bank proposed a new draft regulation in December 2024, intending to include stablecoins in the foreign exchange regulatory system and prohibit transfers to wallets not controlled by Brazilian entities.
Overall, Brazil's regulatory direction is very clear: prioritizing strict control and suppressing high-risk trading scenarios.
Despite the tightening regulations, traditional banks are beginning to explore compliant paths. Brazil's largest bank, Itau Unibanco (with over 55 million customers), is planning to launch a stablecoin pegged to the real. Currently, Itau is studying the experiences of other banks and waiting for the release of Brazil's stablecoin regulatory framework.
