Stablecoin Regulation: Latest Updates from Major Global Regions

In recent years, stablecoins, as a type of cryptocurrency pegged to fiat currencies or other assets, have gained widespread application in areas such as cross-border payments and decentralized finance due to their stable value characteristics. With their rapid development, regulatory agencies in various countries have also begun to pay attention and formulate relevant policies. This article will briefly outline the current regulatory dynamics of stablecoins in major regions around the world.

United States

As one of the main markets for stablecoin development, the regulatory framework in the United States is quite complex, primarily implemented by multiple agencies including the Department of Treasury, the Securities and Exchange Commission (SEC), and the Commodity Futures Trading Commission (CFTC). The SEC may classify some stablecoins as securities, requiring them to comply with relevant regulations. Meanwhile, Congress is discussing proposals such as the "Stablecoin Transparency Act" in an attempt to establish a unified regulatory framework.

European Union

The European Union mainly relies on the "Regulation on Markets in Crypto-Assets" (MiCA) to regulate stablecoins. MiCA categorizes stablecoins into asset-referenced tokens (ART) and electronic money tokens (EMT), and establishes corresponding regulatory requirements. Entities issuing stablecoins must obtain permission from EU member states and meet conditions such as capital reserves and transparency disclosures.

Hong Kong

In July 2024, the Hong Kong Monetary Authority and the Financial Services and the Treasury Bureau released the main content of the stablecoin regulatory system. The system requires companies issuing or promoting fiat stablecoins in Hong Kong to obtain a license from the Monetary Authority and meet relevant requirements in areas such as reserve asset management, corporate governance, and risk control. In addition, Hong Kong has also launched a "sandbox" program for stablecoin issuers to promote communication with the industry. Recently, the government also published the "Stablecoin Bill" in the Gazette, aimed at improving the regulatory framework for virtual asset activities.

Singapore

Singapore views stablecoins as digital payment tokens, and their issuance and circulation require approval from the Monetary Authority of Singapore (MAS). The MAS also provides a regulatory sandbox for startups to test business models related to stablecoins.

Japan

In June 2022, Japan revised the Payment Services Act, establishing a regulatory framework for the issuance and trading of stablecoins. The amended law defines stablecoins fully backed by fiat currency as "Electronic Payment Instruments" (EPI) and stipulates that only three types of institutions—banks, money transfer service providers, and trust companies—can issue stablecoins. Institutions wishing to engage in stablecoin-related activities must first register as Electronic Payment Instrument service providers.

Brazil

The Brazilian Central Bank plans to regulate stablecoins and asset tokenization by 2025. In November 2024, the Central Bank proposed a regulatory proposal suggesting a ban on users withdrawing stablecoins from centralized exchanges to self-custody wallets. However, the Deputy Director of the Financial System at the Central Bank indicated that this ban may be lifted if key issues such as transaction transparency can be improved.

Outlook

As the importance of stablecoins in the global financial system continues to grow, more and more countries and regions are developing or refining related regulatory policies. Whether establishing regulatory sandboxes or classifying regulations based on the different characteristics of stablecoins, there may be more stablecoin regulatory measures in the future. It is worth noting that cross-border payments seem to become one of the most widely used scenarios for stablecoins, which may also influence the future direction of regulation.