Regulation explainerStablecoin Studio

Stablecoin regulation under MiCA, the GENIUS Act and other regimes: what issuers must have in place

A fiat-backed stablecoin is regulated as an instrument and an activity, whatever ledger it runs on. In the EU the starting point is MiCA's e-money token rules; in the US, the GENIUS Act's permitted-issuer regime; the UK, Hong Kong and Singapore have their own. This explainer maps the obligations, separates what Stablecoin Studio can enforce from what only a licensed issuer provides, and sketches a hypothetical launch.

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On this page
  1. Classify the token before reading any rulebook
  2. Issuer obligations in the EU, US, UK, Hong Kong and Singapore
  3. MiCA in practice for an e-money token issuer
  4. GENIUS Act routes and the effective-date trigger
  5. Implementation status outside the EU and US
  6. Where Stablecoin Studio controls meet regulatory obligations
  7. Obligations no tooling can discharge
  8. A hypothetical euro e-money token, from approval to launch
  9. Questions and answers
  10. Sources

Classify the token before reading any rulebook

The same wallet balance can fall into different legal categories, and each category has its own regime.

  • If

    The token references one official currency and is offered to the public or traded in the EU.

    Then

    Treat it as an e-money token under MiCA, Regulation (EU) 2023/1114.

    E-money tokens may only be issued by an authorised credit institution or e-money institution1.

  • If

    It references a basket of currencies, commodities or other assets.

    Then

    Treat it as an asset-referenced token under MiCA's separate authorisation and reserve rules.

    Asset-referenced token issuers must hold a reserve of assets and give holders a permanent right of redemption1.

  • If

    It is a dollar-denominated token for payments offered to people in the United States.

    Then

    Assess it as a payment stablecoin under the GENIUS Act and identify the permitted-issuer route.

    Only permitted payment stablecoin issuers may issue payment stablecoins once the Act takes effect3.

  • If

    It represents a deposit held at your bank and stays a claim on the bank.

    Then

    Analyse it as a tokenised deposit under banking law rather than as a stablecoin.

    MiCA excludes crypto-assets that qualify as deposits, under Article 2(4)(b)1.

Issuer obligations in the EU, US, UK, Hong Kong and Singapore

Markets in Crypto-Assets Regulation (Regulation (EU) 2023/1114), Title IV e-money tokens

European Union

Applies whenAn e-money token is offered to the public or admitted to trading in the Union1.

  • Authorisation as a credit institution or electronic money institution.
  • A crypto-asset white paper notified to the competent authority and published.
  • Issuance at par and redemption at par value, at any time, on the holder's request.
  • No interest granted to holders, and funds received invested in assets denominated in the referenced currency.
  • Additional requirements, including higher capital and liquidity policies, if the token is classified as significant.

Markets in Crypto-Assets Regulation (Regulation (EU) 2023/1114), Title III asset-referenced tokens

European Union

Applies whenA token referencing a basket or other assets is offered or admitted to trading in the Union1.

  • Authorisation by the home competent authority, or a credit institution's notified, approved white paper.
  • A reserve of assets kept at all times, a permanent redemption right and no interest to holders.

GENIUS Act (Guiding and Establishing National Innovation for U.S. Stablecoins Act)

United States

Applies whenA payment stablecoin is issued or offered to people in the United States once the Act takes effect23.

  • Approval as a permitted issuer: a subsidiary of an insured depository institution, a federal qualified issuer approved by the OCC, or a state qualified issuer3.
  • Identifiable reserves of at least one dollar per token, limited to assets such as insured deposits, short-term Treasuries, Treasury-backed repos and qualifying money market funds3.
  • Monthly public disclosure of reserve composition, published redemption procedures and fees3.
  • No interest or yield paid to holders solely for holding the token3.

Stablecoins Ordinance (Cap. 656)[^5]

Hong Kong

Applies whenA person issues fiat-referenced stablecoins as a regulated activity in Hong Kong, in force since 1 August 20255.

  • A licence from the Hong Kong Monetary Authority, which keeps a public register of licensed issuers5.
  • Compliance with the HKMA's supervisory and anti-money-laundering guidelines for stablecoin issuers5.

MAS stablecoin regulatory framework

Singapore

Applies whenA single-currency stablecoin pegged to the Singapore dollar or a G10 currency is issued in Singapore and seeks recognition6.

  • Reserve assets meeting composition, valuation, custody and audit requirements6.
  • Return of par value within five business days of a redemption request6.
  • Minimum base capital and liquid assets, plus disclosures; only compliant issuers may use the MAS-regulated stablecoin label6.

FCA cryptoasset regime for qualifying stablecoins

United Kingdom

Applies whenA firm issues a qualifying stablecoin in the UK under the new regulated activities created by HM Treasury legislation4.

  • Authorisation under the Financial Services and Markets Act 2000 for the new activity4.
  • FCA rules on maintaining value, managing backing assets and informing holders, with separate prudential rules for issuers4.

MiCA in practice for an e-money token issuer

MiCA's stablecoin titles have applied since 30 June 20241. For a fiat-backed token referencing one currency, the decisive rule is in Article 48: only a credit institution or an electronic money institution may offer it, and only after notifying a white paper to its competent authority1. A fintech without either authorisation must obtain one or work with an institution that holds it.

The holder's position is defined in law rather than in terms and conditions. Holders have a claim on the issuer, tokens are issued at par on receipt of funds, and redemption at par must be available at any time on the holder's request. Neither the issuer nor crypto-asset service providers may pay interest on the token1. Reserve funds must be held in assets denominated in the same currency the token references, to avoid currency mismatch1.

Scale changes the supervisor. A token classified as significant, judged on criteria such as holder numbers, market capitalisation and transaction volumes, carries higher capital and liquidity requirements and closer supervision involving the European Banking Authority1.

GENIUS Act routes and the effective-date trigger

The GENIUS Act was signed on 18 July 20253. It creates three routes to becoming a permitted payment stablecoin issuer: a subsidiary of an insured bank, a federal qualified issuer approved by the OCC, or a state qualified issuer supervised under a state regime that Treasury certifies as substantially similar3. A nonbank issuer may stay on a state route while its outstanding issuance remains under $10 billion3.

Payment stablecoins are defined so as to exclude deposits3. Issuers must hold at least one dollar of permitted reserves per token, publish reserve composition monthly, disclose redemption procedures and fees, and must not pay holders interest or yield for simply holding the token3.

The Act takes effect on the earlier of 18 months after enactment or 120 days after the primary regulators issue final implementing rules3. Treat January 2027 as the outer date3 and check the OCC, FDIC, Federal Reserve and Treasury rulemaking record before fixing a launch plan, because a final rule could bring the date forward.

Implementation status outside the EU and US

Where Stablecoin Studio controls meet regulatory obligations

Controls come from the Stablecoin Studio repository7. Each supports an obligation; none discharges it alone.

ObligationStablecoin Studio controlStill needed outside the software
Customer due diligencePer-account KYC flag granted or revoked by the KYC roleIdentity verification, screening, ongoing monitoring and records
Sanctions and legal ordersFreeze, wipe and pause rolesScreening decisions, legal review and the authority to act
Supply matched to reservesCash-in allowances and a reserve check before mintingThe reserves themselves, held with eligible banks or custodians
Segregation of dutiesSeparate roles and multi-signature approval with key lists or threshold keysWho holds each key, and the policy for granting roles
Redemption at parBurn role and treasury account for returned tokensPayout operations, service levels and liquidity to meet requests
Disclosure and attestationReserve feed and a ledger history anyone can queryAttestation by an independent accounting firm and published reports

Obligations no tooling can discharge

A hypothetical euro e-money token, from approval to launch

For example, an EU e-money institution might sequence the work like this. The order is illustrative, not legal advice.

  1. Confirm the licence covers the token

    Agree with the competent authority that issuing an e-money token fits the institution's existing authorisation and business plan.

    Owner
    Compliance and counsel

  2. Draft the white paper and holder terms

    Describe the issuer, the redemption right, the reserve investment policy and the technology, including the controls the issuer can apply.

    Owner
    Counsel and product

  3. Set up reserve accounts and investment policy

    Open segregated accounts, agree the eligible euro assets and set the reconciliation cycle with the reserve bank.

    Owner
    Treasury

  4. Build and test on testnet

    Deploy Stablecoin Studio, configure roles, threshold keys and allowances, connect the reserve feed and rehearse mint, freeze and redemption scenarios.

    Owner
    Engineering, with ColdAI

  5. Notify, review and launch in stages

    Notify the authority, complete an independent review of the deployed configuration, then launch to a small set of onboarded customers and reconcile daily.

    Owner
    Compliance and security

Questions and answers

Can a non-bank issue a stablecoin in the EU?

Yes, with the right authorisation. A firm that is not a credit institution can issue an e-money token if it is authorised as an electronic money institution, and can issue an asset-referenced token if its home competent authority authorises it under MiCA. Without one of those, it can still build the technology, but a licensed institution must be the issuer.

Are algorithmic stablecoins covered by these rules?

Not as compliant stablecoins. MiCA's e-money and asset-referenced token rules depend on an identifiable issuer, reserves and a redemption right, and tokens without them fall under MiCA's general crypto-asset rules instead. Under the GENIUS Act, only permitted issuers holding qualifying reserves may issue payment stablecoins in the US once it takes effect.

Does issuing on Hedera change the regulatory analysis?

Not the classification: the rules attach to the instrument, the issuer and the activity, whichever ledger is used. The network does affect how obligations are met, for example whether the issuer can freeze accounts, require KYC before transfers, and evidence its operational resilience. Those questions belong in the white paper and the issuer's risk assessment.

Sources

  1. Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA) — EUR-Lex · checked 10 October 2026
  2. S.1582 - GENIUS Act, 119th Congress — Congress.gov · checked 10 October 2026
  3. The GENIUS Act: A New Federal Regulatory Framework for Payment Stablecoins — Morrison Foerster · checked 10 October 2026
  4. CP25/14: Stablecoin issuance and cryptoasset custody — Financial Conduct Authority · checked 10 October 2026
  5. Stablecoin issuers — Hong Kong Monetary Authority · checked 10 October 2026
  6. MAS finalises stablecoin regulatory framework — Monetary Authority of Singapore · checked 10 October 2026
  7. Stablecoin Studio repository — Hashgraph on GitHub · checked 10 October 2026

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