Author: Fairy, ChainCatcher
Editor: TB, ChainCatcher
The breakout effect of stablecoins is continuing to amplify.
From the high-frequency topics appearing on Douyin's hot search list to the content creation shift of traditional financial bloggers, and to the active inquiries from relatives and neighbors, stablecoins seem to have become a social buzzword that permeates daily life.
At the same time, the global policy front is also welcoming a key turning point. Over the past year, many countries have shifted their attitude towards stablecoins from cautious observation to acceptance: Hong Kong's (stablecoin regulations) are about to be implemented, the EU's MiCA bill has officially landed, and the United States has passed the (Genius Act). Stablecoins are quietly prying at the foundation of the global monetary system.
This article will systematically sort out the latest dynamics of stablecoin regulation in various countries and analyze the underlying logic and strategic implications of this financial transformation.
A glance at the global stablecoin regulatory situation.
Analyzing the evolution of stablecoin policies in twelve core global markets.
United States: State division and competitive layout
Policy progress speed: ★★★★
The development of stablecoins in the United States shows a 'federal + state-level' dual-track advancement. On one hand, the federal government is accelerating the unification of the regulatory framework; on the other hand, various states are taking the lead in piloting and pushing for institutional implementation.
At the state level, many places have taken the lead in implementing specific regulations and regulatory frameworks:
Wyoming passed the (Wyoming Stablecoin Act) in 2023, establishing the 'Wyoming Stablecoin Committee' and plans to issue a state-supported stablecoin WYST on August 20, 2025.
The New York Department of Financial Services required stablecoin issuers to obtain a BitLicense or trust company license and comply with strict regulations as early as 2018.
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.
Federal-level regulatory legislation is also rapidly advancing:
(GENIUS Act) was signed into effect by Trump on July 19, 2025.
This bill requires: prohibition of issuing yield-bearing stablecoins, monthly disclosure of reserve composition with audits, and the CEO and CFO responsible for the authenticity of the data. Issuers can choose to be regulated by federal or state authorities, with small issuers (issuance amount < 10 billion USD) allowed to choose state-only regulation.
(STABLE Act) was proposed in March 2025, currently passed the House review and awaits Senate voting. The draft of this bill is largely similar to the GENIUS Act.
China: Hong Kong leads, mainland observes
Policy progress speed: Hong Kong ★★★★ | Mainland ★
A regulatory linkage pattern of 'outpost + local' has formed between mainland China and Hong Kong regarding stablecoin regulation: Hong Kong has taken the lead in establishing a mature regulatory system to accelerate the attraction of enterprises while the mainland maintains caution at the policy level.
In Hong Kong, its (stablecoin regulations) will officially take effect on August 1, 2025.
Currently, about 50 to 60 companies have expressed their intention to apply, half of which are payment institutions and the other half are major internet platforms, most of which have Chinese backgrounds. JD.com, Standard Chartered, and Ant Group have initiated related preparations, and the industry expects only 3 to 4 licenses to be issued in the first batch, with a high entry threshold.
It is reported that the first batch of licenses may adopt an 'invitation application system' rather than a unified open application, with initial stablecoins mainly pegged to the Hong Kong dollar and the US dollar.
On the mainland, there has long been a 'preventive suppression' stance, but recently several provinces and cities have signaled research and attention towards stablecoins.
On July 7, the Wuxi Municipal Committee proposed exploring 'stablecoins empowering foreign trade development' to expand new space for digital trade.
On July 9, the official public 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 study meeting focusing on the development trends of cryptocurrencies and stablecoins and response strategies.
On July 18, the China Industrial Internet Research Institute hosted a 'Stablecoins and Industrial Digital Assets Seminar.'
South Korea: Attitude shifts, bank alliances accelerate layout
Policy progress speed: ★★★
South Korea is undergoing a transition from 'watching' to 'entering the market'. Against the backdrop of the new President Lee Jae-myung promising to support the development of a won stablecoin, on June 10, the ruling party officially proposed the (Basic Law on Digital Assets), intending to allow local companies with capital exceeding 368,000 USD to issue stablecoins, marking a loosening at the policy level.
Currently, the eight major banks in South Korea are preparing to establish a joint venture company, planning to jointly issue a won stablecoin. Participating institutions include the National Bank, Shinhan Bank, Woori Bank, Nonghyup Bank, Korea Industrial Bank, Suhyup Bank, as well as the Korean branches of Citibank and Standard Chartered. This 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 go online by the end of this year or early next year.
However, current regulation remains in an uncertain state. According to the analysis of 100y.eth, the research director of Four Pillars, South Korea is currently experiencing a stablecoin bubble, and there is no clear guidance on regulation. Financial news almost daily reports banks or companies applying for stablecoin-related trademarks, and the stock prices of related listed companies usually rise 15%-30% on the same day.
Thailand: Policy opens, cautiously testing the waters
Policy progress speed: ★★★
Thailand's stablecoin policy has gradually shifted from early vigilance to cautious piloting. As early as 2021, the Bank of Thailand began exploring stablecoin regulation, releasing preliminary guidelines. Among them, stablecoins pegged to the baht are considered 'electronic money' regulated by the (Payment Systems Act), and relevant institutions must consult the central bank for approval before issuance; while stablecoins pegged to foreign currencies (such as USDT, USDC) have not been prohibited but require further regulation.
A real turning point occurred in 2024. In August, Thailand established a regulatory sandbox allowing specific service providers to experiment with cryptocurrencies.
In 2025, the pilot scope will accelerate expansion:
In January, the Thai Finance Minister stated at a Securities and Exchange Commission meeting that the government is considering issuing a stablecoin backed by 10 billion baht in government bonds.
In March, the Thai Securities and Exchange Commission (SEC) approved USDT and USDC as tradable assets in 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 baht through licensed platforms for travel consumption.
EU: Unified regulation, cautious support.
Policy progress speed: ★★★★★
The EU's attitude towards the development of stablecoins can be summed up as 'cautious support': fully affirming the potential of stablecoins while maintaining a high vigilance against financial stability, regulatory arbitrage, and money laundering risks.
In June 2023, the EU officially released the (Crypto Asset Markets Regulation) (MiCA), with the core goal of comprehensively regulating the crypto asset market. Some provisions will take effect on June 30, 2024, and stablecoin-related provisions will be fully implemented by December 30, 2024. This bill applies to all 27 EU member states and the three countries of Norway, Iceland, and Liechtenstein within the European Economic Area (EEA).
MiCA sets high thresholds for the issuance and operation of stablecoins: issuers must obtain authorization from member state regulatory agencies (such as Germany's BaFin, France's AMF) and establish legal entities in the EU. Stablecoins that meet 'significance' criteria (for example, with huge transaction volumes) will be regulated uniformly by the European Banking Authority (EBA).
MiCA also stipulates that daily transactions of stablecoins denominated in currencies other than the euro cannot exceed 1 million transactions or 200 million euros in any currency area. 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 companies, including 14 stablecoin issuers and 39 crypto asset service providers.
Singapore: Early start, high standards.
Policy progress speed: ★★★★★
Singapore is at the forefront of 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 of the (Stablecoin Regulatory Framework) in December 2022 and initiated public consultation, officially launching the final version on August 15, 2023. This regulatory framework specifically applies to single-currency stablecoins (SCS) issued in Singapore that are pegged to the Singapore dollar (SGD) or G10 currencies and is included as supplementary provisions under the (Payment Services Act).
MAS has set high entry thresholds, and issuers must meet the following requirements:
The capital of stablecoin issuers must be no less than 50% of annual operating expenses or 1 million Singapore dollars.
Stablecoin issuers are prohibited from engaging in trading, asset management, staking, lending, and other businesses, and must not directly hold shares of other legal entities.
Liquid assets must meet the scale necessary for normal withdrawal needs or exceed 50% of annual operating expenses.
The reserve assets of stablecoin issuers can only consist of the following low-risk, highly liquid assets: cash, cash equivalents, and 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 (issuer of XSGD) and Paxos are regarded as pioneering compliant case studies.
UAE: Actively promoting, dual-track parallel.
Policy progress speed: ★★★★★
The UAE has shown a supportive and open attitude towards stablecoin policies. In June 2024, the UAE Central Bank issued (Payment Token Service Regulations), clarifying the definition and regulatory framework for 'payment tokens' (stablecoins).
The UAE, as a federal country composed of seven emirates, has a distinctive 'dual-track' regulatory feature: the central bank is responsible for regulation at the federal level, while the Dubai International Financial Centre (DIFC) and the Abu Dhabi Global Market (ADGM) serve as financial free zones with independent legal systems and regulatory authority.
Compared to the EU (MiCA) or Hong Kong (stablecoin regulations), the UAE's new regulations are relatively broad in defining stablecoins, but still set certain boundaries:
Prohibit the issuance of algorithmic stablecoins and privacy tokens.
Stablecoins are not allowed to pay users interest or other returns linked to the duration of holding tokens.
In specific applications, the stablecoin market in the UAE has also begun to show results. In December 2024, AE Coin received approval from CBUAE, becoming the UAE's first fully regulated dirham stablecoin.
In April 2025, Abu Dhabi Sovereign Wealth Fund ADQ, corporate group IHC, and the largest asset-sized bank in the UAE, First Abu Dhabi Bank, jointly announced the launch of a new stablecoin pegged to the dirham.
Japan: Regulation leads, development awaits to start
Policy progress speed: ★★★★
Japan is at the forefront of global stablecoin regulation, having completed the foundational legislative framework first. Its regulatory path is mainly achieved through the (Payment Services Act) (PSA).
In June 2022, Japan's National Assembly passed a revised version of the (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 trading. It limits stablecoin issuers to three categories: banks, trust companies, and money transfer service providers.
In March 2025, Japan's Financial Services Agency promoted the (2025 Payment Services Act Amendment) to optimize the stablecoin issuance mechanism: allowing trust-type stablecoins to use up to 50% of reserve assets for specific low-risk instruments, such as short-term government bonds or time deposits. This law also introduced a specialized registration category for crypto intermediaries, lowering the participation threshold for over-the-counter trading.
Russia: Primarily exploratory, still limited to external use.
Policy progress speed: ★★
Russia's attitude towards stablecoins has seen a significant shift in recent years, from initial caution or even opposition to limited support, mainly due to strategic demands for cross-border settlements 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, the policy direction saw a key turn. The Federal Assembly of Russia 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. However, within the domestic sphere, cryptocurrencies are still not allowed to be used as a means of payment.
In March 2025, the Central Bank of Russia released a proposal to allow 'specially qualified' high-net-worth individuals and certain 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 its own sovereign stablecoin to adapt to the evolving trends of the global payment system.
UK: Regulation is advancing.
Policy progress speed: ★★
The UK's policy is currently at a crucial transitional stage from framework design to legislative implementation. The relevant regulatory system is based on the (2023 Financial Services and Markets Act) and supplemented by secondary regulations and regulatory guidelines formulated by the Financial Conduct Authority (FCA) and the Bank of England (BoE). This bill was Royal Assent on June 29, 2023, and for the first time brought 'digital settlement assets' (including stablecoins) into the legal realm of regulated financial activities.
In November 2023, the UK's Financial Regulatory Authority announced regulatory requirements for companies issuing or custody fiat-backed stablecoins. The proposed framework will seek to apply several existing regulatory standards currently applicable to many FCA-authorized entities to the realm of stablecoin activities.
In April 2025, the UK government released a consultation paper on legislative drafts in the cryptocurrency field, planning to add regulated activities including operating crypto asset trading platforms and stablecoin issuance.
Despite continuous regulatory progress, the Governor of the Bank of England has shown a more conservative stance. Governor Andrew Bailey has publicly stated multiple times that the widespread use of stablecoins could undermine public trust in the national currency and even pose systemic risks to the financial system.
Canada: Regulation is vague, and the regulatory framework is taking shape.
Policy progress speed: ★★
Compared to markets like 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 Canadian securities regulators (CSA) subsequently tightened policies, bringing stablecoins under the regulation of 'securities and/or derivatives.'
Since 2023, CSA has published two key documents SN 21332 and SN 21333, proposing a regulatory framework for 'fiat-backed stablecoins'. According to relevant regulations, stablecoin issuers need to register as securities issuers and submit a prospectus or sign a commitment letter recognized by CSA.
Last month, Canadian banking regulators indicated that they are ready to regulate stablecoins, and a regulatory framework is being developed.
Brazil: Strict control orientation.
Policy progress speed: ★
Data from the Brazilian central bank shows that over 90% of the country's cryptocurrency trading involves stablecoins, primarily used for cross-border payments, but this trend has also raised compliance concerns.
Gabriel Galipolo, the President of the Brazilian Central Bank, stated that the central bank initially believed the popularity of stablecoins was due to their provision of a convenient way for the public to hold dollars. However, after in-depth research, it was 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 activities.
To this end, the Brazilian Central Bank 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: prioritize suppressing high-risk trading scenarios under strong control.
Despite tightening regulations, traditional banks are beginning to explore compliance pathways. Brazil's largest bank, Itau Unibanco (with over 55 million customers), plans to launch a stablecoin pegged to the real. Currently, Itau is researching the relevant experiences of other banks and waiting for the Brazilian stablecoin regulatory framework to be established.
