Breaking the circle in progress: A big comparison of the regulatory policies of stablecoins in 12 countries

ChainCatcher

The breakthrough influence of stablecoins continues to expand.

From the frequent appearance of related topics on Douyin's trending search list, to the collective shift of traditional financial bloggers in their content creation, and even to the active inquiries from relatives and neighbors around, stablecoins seem to have become a social buzzword that permeates daily life.

Meanwhile, a crucial turning point has been reached in global policies. Over the past year, many countries have shifted their attitude towards stablecoins from cautious observation to acceptance: Hong Kong's "Stablecoin Ordinance" is about to be implemented, the EU's MiCA bill has officially taken effect, and the United States has passed the "Genius Act". Stablecoins are quietly shaking the foundation of the global monetary system.

This article will systematically sort out the latest developments in stablecoin regulation across various countries and analyze the underlying logic and strategic implications of this financial reform.

A Glance at the Global Stablecoin Regulatory Landscape

Analyzing the Evolution of Stablecoin Policies in the World's Twelve Core Markets

United States: Separate Governance by States and Federation, Rushing for Layout

Policy Progress Speed: ★★★★

The development of stablecoins in the United States presents a dual-track advancement of "federal + state levels". On one hand, the federal government is accelerating the unification of regulatory frameworks at the legislative level; on the other hand, various states are taking the lead in trials to promote the implementation of systems.

At the state level, many regions have taken the lead in introducing specific regulations and regulatory frameworks:

Wyoming passed the "Wyoming Stablecoin Act" in 2023, established the "Wyoming Stablecoin Commission", and plans to issue the state-supported stablecoin WYST on August 20, 2025.

As early as 2018, the New York State Department of Financial Services required stablecoin issuers to obtain a BitLicense or a trust company license and comply with strict regulations.

California passed the "Digital Financial Assets Act" (DFAL) in 2023, establishing a comprehensive licensing system covering stablecoin issuers. DFAL will officially take effect in July 2026.

Regulatory legislation at the federal level is also advancing rapidly:

The "GENIUS Act" was signed into law by Trump on July 19, 2025.

The act stipulates: prohibiting the issuance of interest-bearing stablecoins, requiring monthly disclosure of reserve composition with audit, and holding CEOs and CFOs responsible for the authenticity of data. Issuers can choose to be regulated by either federal or state authorities, and small issuers (with an issuance amount of less than 10 billion U.S. dollars) can opt to be regulated only by the state.

The "STABLE Act", proposed in March 2025, has passed the House of Representatives and is awaiting a Senate vote. The content of this bill draft is largely the same as the GENIUS Act.

China: Hong Kong Takes the Lead in Policies, Mainland Remains Observant

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

Mainland China and Hong Kong have formed a "outpost + local" linkage pattern in stablecoin regulation: Hong Kong takes the lead in establishing a mature regulatory system to accelerate the attraction of enterprises to settle in; while the mainland remains cautious at the policy level.

In Hong Kong, its "Stablecoin Ordinance" will officially come into effect on August 1, 2025.

Currently, about 50 to 60 enterprises have expressed their intention to apply, half of which are payment institutions and the other half are large Internet platforms, most of which have Chinese capital backgrounds. JD.com, Standard Chartered, Ant Group, etc. have started relevant preparations, and the industry expects that only 3 to 4 licenses will be issued in the first batch, with a high entry threshold.

It is reported that the first batch of licenses may adopt an "invitation-based application system" instead of a unified public application, and the initial stablecoins will mainly be pegged to the Hong Kong dollar and the U.S. dollar.

In the mainland, there has long been a situation of "preventive suppression", but recently, several provinces and cities have released signals of research and attention to stablecoins.

On July 7, the reform promotion meeting of the Wuxi Municipal Party Committee proposed to explore "stablecoins empowering foreign trade development" and expand new spaces for digital trade;

On July 9, the official WeChat account of the Jinan Municipal People's Government Research Office released a special article on stablecoins written by Xinhua News Agency;

On July 10, the Party Committee of the Shanghai State-owned Assets Supervision and Administration Commission held a central group study session to conduct studies on the development trends and coping strategies of cryptocurrencies and stablecoins;

On July 18, the China Academy of Industrial Internet hosted the "Seminar on Stablecoins and Industrial Digital Assets".

South Korea: Attitude Shift, Banking Alliance Accelerates Layout

Policy Progress Speed: ★★★

South Korea is undergoing a transformation from "observation" to "entry into the market". Against the backdrop of the new President Lee Jae-myung's promise to support the development of won-denominated stablecoins, on June 10, the ruling party of South Korea formally proposed the "Basic Law on Digital Assets", intending to allow local enterprises with capital exceeding 368,000 U.S. dollars to issue stablecoins, marking a relaxation at the policy level.

At present, South Korea's eight major banks are preparing to establish a joint venture company, planning to jointly issue won-denominated stablecoins. Participating institutions include Kookmin Bank, Shinhan Bank, Woori Bank, Nonghyup Bank, Korea Development Bank, Suhyup Bank, and the Korean branches of two foreign banks, Citibank and Standard Chartered. The project is jointly promoted by the eight banks, the Open Blockchain and Decentralized Identity Association, and the Financial Supervisory Service. If approved by regulators, it is expected to be launched by the end of this year or early next year.

However, the current regulation is still in an uncertain state. According to 100y.eth, research director of Four Pillars, South Korea is currently experiencing a stablecoin bubble, and there is no clear regulatory guidance. Financial news reports almost daily that banks or enterprises are applying for stablecoin-related trademarks, and the stock prices of related listed companies usually rise by 15%-30% on the same day.

Thailand: Policy Gate Opened, Cautious Trial

Policy Progress Speed: ★★★

Thailand's stablecoin policy has gradually moved from early vigilance to prudent trials. As early as 2021, the Bank of Thailand initiated the exploration of stablecoin regulation and released preliminary guidelines. Among them, stablecoins pegged to the Thai baht are regarded as "electronic money" and are regulated by the "Payment Systems Act". Relevant institutions need to consult the central bank for approval before issuance; while stablecoins pegged to foreign currencies (such as USDT, USDC) are not prohibited but require further regulation.

A real turning point occurred in 2024. In August, Thailand established a regulatory sandbox, allowing specific service providers to try out cryptocurrencies.

In 2025, the scope of trials has been expanded at an accelerated pace:

In January, the Thai Minister of Finance stated at a meeting of the Securities and Exchange Commission that the government is considering issuing stablecoins supported by 10 billion baht in government bonds.

In March, the Securities and Exchange Commission (SEC) of Thailand approved USDT and USDC as tradable assets to enter the country's regulated exchanges.

In July, the SEC and BOT jointly launched a "national-level crypto sandbox", allowing foreign tourists to exchange digital assets (such as USDT, USDC) for Thai baht through licensed platforms for tourism consumption.

European Union: Unified Regulation, Cautious Support

Policy Progress Speed: ★★★★★

The EU's attitude towards the development of stablecoins can be summed up as "cautious support": it fully affirms the potential of stablecoins while maintaining a high level of vigilance against risks such as financial stability, regulatory arbitrage, and money laundering.

In June 2023, the EU officially released the "Markets in Crypto-Assets Regulation" (MiCA), whose core goal is to comprehensively regulate the crypto asset market. Some provisions came into effect on June 30, 2024, and the stablecoin-related provisions were fully implemented on December 30, 2024. The bill applies to the 27 EU member states and the three countries in the European Economic Area (EEA) - Norway, Iceland, and Liechtenstein.

MiCA sets high thresholds for the issuance and operation of stablecoins: issuers must obtain authorization from the regulatory authorities of member states (such as Germany's BaFin, France's AMF) and establish a legal entity in the EU. For stablecoins that meet the "significance" standard (for example, with huge trading volumes), they will be uniformly regulated by the European Banking Authority (EBA).

MiCA also stipulates that stablecoins denominated in non-euro currencies shall not exceed 1 million transactions or 200 million euros per day in any currency area. Once exceeding the limit, 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 at the forefront in stablecoin regulation. As early as December 2019, Singapore introduced the "Payment Services Act", clarifying the definition and classification of payment service providers.

Subsequently, the Monetary Authority of Singapore (MAS) released a draft "Stablecoin Regulatory Framework" in December 2022 and launched public consultations, and officially introduced the final version on August 15, 2023. This regulatory framework is specifically applicable to single-currency stablecoins (SCS) issued in Singapore and pegged to the Singapore Dollar (SGD) or G10 currencies, and is incorporated into the regulatory system as a supplementary clause to the "Payment Services Act".

MAS has set high entry thresholds, and issuers must meet the following requirements:

The capital of the stablecoin issuer is not less than 50% of the annual operating expenses or 1 million Singapore dollars;

Stablecoin issuers shall not engage in other businesses such as trading, asset management, staking, lending, nor directly hold shares of other legal entities;

Liquid assets meet the scale required for normal withdrawal of assets or are higher than 50% of annual operating expenses.

The reserve assets of the stablecoin issuer can only consist of the following extremely low-risk and highly liquid assets: cash, cash equivalents, bonds with a remaining maturity of no more than three months.

Currently, several institutions have applied to MAS for stablecoin issuance qualifications. Among them, StraitsX (the issuer of XSGD) and Paxos are regarded as the first demonstration cases of compliant implementation.

United Arab Emirates: Actively Promoting, Dual-Track Parallel

Policy Progress Speed: ★★★★★

The United Arab Emirates has shown a supportive and open attitude towards stablecoin policies. In June 2024, the Central Bank of the UAE issued the "Payment Token Service Regulations", clarifying the definition and regulatory framework of "payment tokens" (stablecoins).

As a federal country composed of seven emirates, the UAE's regulatory system has distinct "dual-track" characteristics: the central bank is responsible for regulation within the federal scope, while the Dubai International Financial Centre (DIFC) and Abu Dhabi Global Market (ADGM), as financial free zones, enjoy independent legal systems and regulatory powers.

Compared with the EU's MiCA or Hong Kong's "Stablecoin Ordinance", the new regulations in the UAE have a relatively broad definition of stablecoins but still set certain boundaries:

Prohibition on the issuance of algorithmic stablecoins and privacy tokens;

Stablecoins are not allowed to pay users interest or other returns linked to the holding time.

In terms of specific applications, the stablecoin market in the UAE has also achieved 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, a conglomerate, and First Abu Dhabi Bank, the largest bank in the UAE by assets, jointly announced that they would launch a new stablecoin pegged to the dirham.

Japan: Regulation First, Development to be Launched

Policy Progress Speed: ★★★★

Japan is at the forefront of global stablecoin regulation and has taken the lead in completing the basic legislative framework. Its regulatory path is mainly realized through improvements to the "Payment Services Act" (PSA).

In June 2022, the Japanese Diet passed the revised "Payment Services Act", which officially came into effect in June 2023. The revised law defines stablecoins in detail, clarifies the issuing entities, and lists the licenses required for stablecoin transactions. It limits stablecoin issuers to three categories: banks, trust companies, and money transfer service providers.

In March 2025, the Japanese Financial Services Agency promoted the "2025 Amendment to the Payment Services Act" to optimize the stablecoin issuance mechanism: trust-based stablecoins are allowed to use up to 50% of their reserve assets for specific low-risk instruments, such as short-term government bonds or time deposits. The law also adds a special registration category for crypto intermediaries, lowering the threshold for participation in over-the-counter transactions.

Russia: Mainly Exploring, Still Restricting External Use

Policy Progress Speed: ★★

Russia's attitude towards stablecoins has undergone a significant change in recent years, from initial caution or even opposition to limited support. This change is mainly due to the strategic needs for cross-border settlement and an independent financial system under geopolitical pressure.

In 2022, the Central Bank of Russia promoted a comprehensive ban on cryptocurrencies. However, in July 2024, there was a crucial turning point in the policy direction. 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 overseas partners. But in the domestic field, cryptocurrencies are still not allowed to be used as a means of payment.

In March 2025, the Central Bank of Russia released a proposal, planning 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.

Beyond the policy context, Ivan Chebeskov, head of the Digital Financial Assets Department of the Ministry of Finance, publicly stated that Russia should consider launching its own sovereign stablecoin to adapt to the evolution trend of the global payment system.

United Kingdom: Regulation in Progress

Policy Progress Speed: ★★

British policy is in a crucial transitional stage from framework design to legislative implementation. The relevant regulatory system is based on the "Financial Services and Markets Act 2023", supplemented by secondary regulations and regulatory guidelines formulated by the Financial Conduct Authority (FCA) and the Bank of England (BoE). The act received royal assent on June 29, 2023, and for the first time included "digital settlement assets" (including stablecoins) in the legal scope of regulated financial activities.

In November 2023, the UK Financial Conduct Authority announced regulatory requirements for companies issuing or hosting fiat-backed stablecoins. The proposed framework will seek to apply several existing regulatory standards that already apply to many FCA-authorized entities to the field of stablecoin activities.

In April 2025, the UK government released a consultation document on draft legislation in the cryptocurrency field, planning to add regulated activities, including operating crypto asset trading platforms and issuing stablecoins.

Despite the continuous progress of regulations, the Governor of the Bank of England has shown a more conservative stance. Its Governor Andrew Bailey has publicly stated on multiple occasions that the large-scale application of stablecoins may weaken public trust in the country's currency and even pose systemic risks to the financial system.

Canada: Ambiguous Laws, Regulation in Formation

Policy Progress Speed: ★★

Compared with markets such as the United States and the EU, Canada's policies are more conservative, and the local stablecoin market is developing slowly.

In December 2022, the collapse of FTX triggered turmoil in the global crypto market, and the Canadian Securities Administrators (CSA) subsequently tightened policies, bringing stablecoins into the regulatory scope of "securities and/or derivatives".

Since 2023, CSA has successively released two key documents, SN 21332 and SN 21333, proposing a regulatory framework for "fiat-pegged stablecoins". According to relevant regulations, stablecoin issuers need to register as securities issuers, submit prospectuses, or sign commitments recognized by CSA.

Last month, Canadian banking regulators stated that they are ready to regulate stablecoins, and the regulatory framework is being formulated.

Brazil: Strict Control Orientation

Policy Progress Speed: ★

Data from the Central Bank of Brazil shows that more than 90% of cryptocurrency transactions in the country involve stablecoins, mainly used for cross-border payments, but this trend has also raised compliance concerns.

Gabriel Galipolo, Governor of the Central Bank of Brazil, said that the central bank initially believed that the popularity of stablecoins was because they provided people with a convenient way to hold U.S. dollars. However, in-depth research found that a large number of stablecoin transactions are related to cross-border shopping, and the transaction methods are opaque, which may be used to evade taxes or engage in money laundering activities.

To this end, the Central Bank of Brazil proposed a new regulation draft in December 2024, intending to bring stablecoins into the foreign exchange regulatory system and prohibit transfers to wallets controlled by non-Brazilian entities.

Overall, Brazil's regulatory direction is very clear: on the premise of strong control, priority is given to suppressing high-risk transaction scenarios.

Despite stricter regulations, traditional banks have begun to explore compliant paths. Itau Unibanco, Brazil's largest bank (with more than 55 million customers), is planning to launch a stablecoin pegged to the real. Currently, Itau is studying the relevant experiences of other banks and waiting for the introduction of Brazil's stablecoin regulatory framework.

Disclaimer: The views in this article only represent the author's personal opinions and do not constitute investment advice for this platform. This platform does not make any guarantees regarding the accuracy, completeness, originality, and timeliness of the article's information, nor does it assume any responsibility for any losses caused by the use or reliance on the article's information.