Original Article Title: "Stablecoin Breaking the Circle: In-depth Analysis of the Regulatory Race of Stablecoin Policies in 12 Countries"
Original Article Author: Fairy, ChainCatcher

The stablecoin's circle-breaking effect is continuing to amplify.

From the frequently trending topics on Douyin's hot search list to the content creation shift by traditional financial bloggers, and even to proactive inquiries from relatives and neighbors, stablecoins seem to have become a ubiquitous term in everyday society.

At the same time, there has been a key turning point in global policy. Over the past year, many countries have shifted from a cautious wait-and-see attitude towards stablecoins to acceptance: Hong Kong's "Stablecoin Ordinance" is about to be implemented, the EU's MiCA Proposal has officially landed, and the US has passed the "GENIUS Act." Stablecoins are quietly levering the foundation of the global monetary system.

This article will systematically review the latest developments in stablecoin regulation in various countries, analyzing the underlying logic and strategic implications of this financial revolution.

Global Stablecoin Regulation Trends at a Glance

Analyze the Evolution of Stablecoin Policies in Twelve Core Global Markets

United States: State-Federal Division, Competitive Layout

Policy Progress Speed: ★★★★

The development of stablecoins in the United States has shown a dual-track progression of "federal + state-level." On the one hand, the federal government is accelerating the establishment of a unified regulatory framework through legislation; on the other hand, various states are taking the lead in experimenting and promoting institutional implementation.

At the state level, many regions have already implemented specific regulations and regulatory frameworks:

Wyoming passed the "Wyoming Stablecoin Act" in 2023, establishing the "Wyoming Stablecoin Committee," and plans to issue the state-backed stablecoin, WYST, on August 20, 2025.

The New York Department of Financial Services required stablecoin issuers in 2018 to obtain a BitLicense or trust company charter and comply with strict regulations.

California passed the "Digital Financial Asset Law" (DFAL) in 2023, creating a comprehensive licensing system that includes stablecoin issuers. DFAL will officially take effect in July 2026.

Regulatory legislation at the federal level is also rapidly advancing:

The "GENIUS Act" was signed by Trump on July 19, 2025, and came into effect.

The bill requires: banning the issuance of yield-bearing stablecoins, monthly disclosure of reserve composition with audit, and CEO and CFO accountability for data accuracy. Issuers can choose between federal or state regulation, with small issuers (issuance amount <100 billion USD) given the option to opt for state regulation only.

The STABLE Act was proposed in March 2025, has currently passed the House deliberation, and is awaiting the Senate vote. The draft content of this bill is largely similar to the GENIUS Act.

China: Hong Kong Takes the Lead, Mainland Takes a Wait-and-See Approach

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

Mainland China and Hong Kong have formed a "pioneering + local" stablecoin regulatory linkage pattern: Hong Kong has established a mature regulatory system in advance, accelerating the attraction of corporate landing, while the mainland has maintained a cautious approach at the policy level.

On the Hong Kong side, its "Stablecoin Ordinance" will officially take effect on August 1, 2025.

Currently, about 50 to 60 companies have expressed their application intentions, half of which are payment institutions, and the other half are large Internet platforms, most of which have Chinese backgrounds. Companies such as JD.com, Standard Chartered, and Ant Group have initiated related preparations. 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" instead of a unified open application process, and the initial stablecoins will mainly be pegged to the Hong Kong dollar and the US dollar.

On the mainland side, it has been in a "preventive suppression" stance for a long time in the past, but recently, several provinces and cities have released signals of research and attention to stablecoins.

On July 7, Wuxi Municipal Party Committee Reform Promotion Meeting proposed to explore "Stablecoin Empowering Foreign Trade Development" to expand new space for digital trade;

On July 9, the Jinan Municipal People's Government Research Office official public account released a stablecoin feature article written by Xinhua News Agency;

On July 10, the Shanghai State-owned Assets Supervision and Administration Commission Party Committee held a central group learning session to study the development trends of cryptocurrency and stablecoins and response strategies;

On July 18, the China Industrial Internet Research Institute hosted the "Stablecoin and Industrial Digital Asset Seminar".

South Korea: Attitude Shifts, Bank Alliance Accelerates Deployment

Policy Progress Speed: ★★★

South Korea is currently experiencing a shift from "wait-and-see" to "getting involved." Against the backdrop of newly elected President Lee Jae-myung's promise to support the development of a Korean won stablecoin, on June 10, the ruling party of South Korea officially introduced the "Digital Asset Basic Law," which aims to allow local companies with capital exceeding $368,000 to issue stablecoins, marking a loosening of policies.

Currently, the eight major banks in South Korea are in the process of establishing a joint venture company to jointly issue a Korean won stablecoin. The participating institutions include the National Bank, Shinhan Bank, Woori Bank, Nonghyup Bank, Industrial Bank of Korea, Suhyup Bank, as well as the Korean branches of Citi and Standard Chartered. This project is jointly promoted by the eight banks, the Open Blockchain and Decentralized Identity Association, and the Financial Services Commission. If regulatory approval is obtained, it is expected to go live by the end of this year or early next year.

However, the current regulatory environment remains uncertain. According to 100y.eth, Research Director of Four Pillars, South Korea is currently experiencing a stablecoin bubble, with no clear guidance on regulation. Financial news outlets report almost daily on banks or companies applying for stablecoin-related trademarks, and the stock prices of related listed companies usually rise by 15%-30% on the day of the news.

Thailand: Policy Opening Up, Cautiously Exploring

Policy Progress Speed: ★★★

Thailand's stablecoin policy has transitioned from early caution to cautious experimentation. As early as 2021, the Bank of Thailand initiated exploration of stablecoin regulation and issued preliminary guidance. In this guidance, stablecoins pegged to the Thai baht are considered "electronic money" and are regulated by the Payment Systems Act; relevant institutions are required to consult with the central bank for approval before issuance. Stablecoins pegged to foreign currencies (such as USDT, USDC) are not prohibited but require further regulation.

The real turning point came in 2024. In August, Thailand established a regulatory sandbox, allowing specific service providers to experiment with cryptocurrency

In 2025, the pilot scope accelerated 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 a 100 billion baht government bond.

In March, the Securities and Exchange Commission (SEC) of Thailand approved USDT and USDC as tradable assets on regulated exchanges in the country.

In July, the SEC and BOT jointly launched a "National Cryptocurrency Sandbox," allowing foreign tourists to exchange digital assets (such as USDT, USDC) for Thai baht through licensed platforms for tourist consumption.

EU: Unified Regulation, Cautious Support

Policy Progress: ★★★★★

The EU's attitude towards stablecoin development can be summed up as "Cautious Support": fully recognizing the potential of stablecoins while maintaining a high level of vigilance on financial stability, regulatory arbitrage, and money laundering risks.

In June 2023, the EU officially released the Markets in Crypto-Assets Regulation (MiCA), with the core goal of comprehensive regulation of the crypto-asset market. Partial provisions of the regulation took effect on June 30, 2024, with stablecoin-related provisions fully implemented on December 30, 2024. This regulation applies to the 27 EU member states and the European Economic Area (EEA), including Norway, Iceland, Liechtenstein, and three other countries.

MiCA sets high thresholds for the issuance and operation of stablecoins: issuers must obtain authorization from a member state regulatory authority (such as Germany's BaFin, France's AMF) and establish a legal entity in the EU. For "significant" stablecoins (e.g., those with significant trading volumes), supervision will be conducted by the European Banking Authority (EBA).

Additionally, MiCA stipulates that stablecoins denominated in a currency other than the euro cannot exceed 1 million transactions or €200 million in daily transactions within any single currency area. If this limit is exceeded, the issuer must suspend the stablecoin's issuance 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: ★★★★★

Singapore is a pioneer in stablecoin regulation. As early as December 2019, Singapore enacted the Payment Services Act, which defined and classified payment service providers.

Subsequently, the Monetary Authority of Singapore (MAS) released a draft Stablecoin Regulatory Framework in December 2022 and initiated public consultation. The final version was officially launched 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 a G10 currency. It is incorporated into the regulatory system as a supplementary provision of the Payment Services Act.

MAS has set a high bar for entry; issuers must meet the following requirements:

The issuer's capital must be at least 50% of the annual operating expenses or SGD 1 million;

A stablecoin issuer may not engage in transactions, asset management, collateralization, lending, or any other businesses, nor hold direct stakes in other legal entities;

Liquidity assets must meet the scale required for normal asset withdrawals or be greater than 50% of annual operating expenses.

The reserve assets of the stablecoin issuer can only consist of assets with extremely low risk and sufficient liquidity, such as 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 considered pioneering compliant cases.

United Arab Emirates: Actively Promoting Dual Tracks

Policy Progress Speed: ★★★★★

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

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

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

Prohibition of issuing algorithmic stablecoins and privacy tokens

Stablecoins are not allowed to pay users interest or other rewards based on holding time

In terms of specific applications, the UAE's stablecoin market has also shown initial success. In December 2024, AE Coin was approved by the CBUAE, becoming the UAE's first fully regulated Dirham stablecoin.

In April 2025, the Abu Dhabi Sovereign Wealth Fund ADQ, the conglomerate IHC, and the UAE's largest bank by assets, First Abu Dhabi Bank, jointly announced the launch of a new Dirham-pegged stablecoin.

Japan: Regulatory Ahead, Development Yet to Begin

Policy Progress Speed: ★★★★

Japan is at the forefront of stablecoin regulation globally and was the first to establish a basic legislative framework. Its regulatory path is mainly achieved through improvements to the Payment Services Act (PSA).

In June 2022, the Japanese National Diet passed a revised version of the Payment Services Act, which officially took effect in June 2023. The amended law provides a detailed definition of stablecoins, specifies the issuing entities, and lists the licenses required to operate a stablecoin exchange. It restricts stablecoin issuance to three types of entities: banks, trust companies, and fund transfer service providers.

In March 2025, the Japanese Financial Services Agency promoted the "2025 Payment Services Act Amendment," which optimized the stablecoin issuance mechanism by allowing trust-based stablecoins 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 introduced a specialized registration category for crypto intermediaries, reducing the barriers to entry for over-the-counter transactions.

Russia: Emphasis on Experimentation, but External Use Restricted

Policy Progress Speed: ★★★

Russia's attitude towards stablecoins has undergone a significant shift in recent years, moving from initial caution or even opposition to limited support. This change is mainly driven by the strategic need for cross-border settlements and an autonomous financial system under geopolitical pressure.

In 2022, the Central Bank of Russia advocated for a comprehensive ban on cryptocurrency. However, in July 2024, there was a key policy reversal. 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 foreign partners. However, within the domestic arena, cryptocurrency still cannot be used as a means of payment.

In March 2025, the Central Bank of Russia proposed allowing "specially qualified" high-net-worth individuals and some businesses to invest in crypto assets during a three-year pilot period to explore a more transparent and controlled market environment.

Outside the policy context, Ivan Chebeskov, head of the Digital Financial Assets Department at the Ministry of Finance, publicly stated that Russia should consider launching a domestic sovereign stablecoin to adapt to the evolving trends in the global payment system.

United Kingdom: Regulatory Progress in Motion

Policy Progress Speed: ★★

The UK's policy is currently at a key juncture transitioning from framework design to legislative implementation. The relevant regulatory framework is based on the 2023 Financial Services and Markets Act and supplemented by secondary regulations and regulatory guidance developed by the Financial Conduct Authority (FCA) and the Bank of England (BoE). This Act received royal assent on June 29, 2023, for the first time bringing "digital settlement assets" (including stablecoins) into the legal scope of regulated financial activities.

In November 2023, the UK Financial Conduct Authority (FCA) announced regulatory requirements for companies issuing or custodying fiat-backed stablecoins. The proposed framework will seek to apply several existing regulatory standards that are currently applicable to many FCA-authorized entities to the stablecoin activities sector.

In April 2025, the UK government released a consultation paper on cryptocurrency legislation, planning to add regulated activities, including operating cryptocurrency exchanges and stablecoin issuance.

Despite ongoing regulatory progress, the Governor of the Bank of England has taken a more conservative stance. The Bank's Governor, Andrew Bailey, has publicly stated multiple times that the widespread use of stablecoins could undermine public trust in the domestic currency and even pose systemic risks to the financial system.

Canada: Regulatory Ambiguity, Regulatory Landscape Taking Shape

Policy Development Speed: ★★

Compared to markets like the United States and the European Union, Canada's policies are more conservative, and the local stablecoin market is developing slowly.

In December 2022, the FTX collapse triggered global cryptocurrency market turbulence, leading the Canadian Securities Administrators (CSA) to tighten policies, bringing stablecoins under the regulation of "securities and/or derivatives."

Since 2023, the CSA has successively released two key documents, SN 21332 and SN 21333, outlining a regulatory framework for "fiat-pegged stablecoins." According to the relevant provisions, stablecoin issuers need to register as securities issuers, submit a prospectus, or sign a CSA-approved commitment letter.

Last month, the Canadian banking regulatory authority stated that it is ready to regulate stablecoins, and a regulatory framework is in the works.

Brazil: Strict Control Orientation

Policy Development Speed: ★

According to the Central Bank of Brazil, over 90% of cryptocurrency transactions in the country involve stablecoins, mainly used for cross-border payments, but this trend has also raised compliance concerns.

The President of the Central Bank of Brazil, Gabriel Galipolo, stated that initially, the central bank believed the popularity of stablecoins was due to their providing the public with a convenient way to hold US dollars. However, upon further investigation, it was found that a significant amount of stablecoin transactions are related to cross-border shopping and conducted in an opaque manner, potentially being used for tax evasion or money laundering activities.

As a result, in December 2024, the Central Bank of Brazil proposed a new rule aiming to include stablecoins in the foreign exchange regulatory system and prohibit transfers to wallets not controlled by Brazilian entities.

Overall, the regulatory direction in Brazil is already very clear: based on strong control, the priority is to suppress high-risk transaction scenarios.

Despite the tightening regulation, traditional banks are beginning to explore compliance 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 relevant experiences of other banks and waiting for the stablecoin regulatory framework in Brazil to be established.

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