Analysis · September 2026

Stablecoin Issuance: five jurisdictions compared

Who can issue a payment stablecoin, and under what conditions? Drawing on the BIS FSI Brief No 33, we compare the regimes of the European Union, Hong Kong, Singapore, the United Kingdom and the United States, and derive an eligibility policy for corporate treasurers.

Tokenisation & StablecoinsRegulation
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01A concentrated market, five issuance regimes

$300–320bnmarket size

Flat since October 2025.

~7%of crypto

Share of stablecoins in total crypto market capitalisation.

~90%two issuers

Share of capitalisation held by the top two issuers.

The comparison covers payment stablecoins and the rules binding the issuing entity, not its group.

DimensionEUHong KongSingaporeUKUS
FrameworkMiCASC OrdinanceSCS frameworkFSMA 2000GENIUS Act
Token categoryE-money tokenSpecified SCMAS-regulatedQualifying SCPayment SC
Bank issuerNotificationSC licenceLicence + sub.Licence + sub.Licence + sub.
Non-bank issuerEMI licenceSC licencePayment licenceSC licenceSC licence
Redemption deadlineAt any timeNext business dayUp to 5 daysNext BD / 24h2 business days
Redemption feesProhibited*AllowedReasonable onlyAllowedAllowed
Reserve self-custodyAllowedNot addressedNot permittedNot permitted**Allowed
Interest to holdersProhibitedProhibitedBarred de factoProhibited***Prohibited
Non-core activitiesCase-by-caseCase-by-caseProhibitedCase-by-caseClosed list

* except stress events (MiCA art. 46(1)) · ** intragroup custodians capped at 20% of the backing pool (FCA) · *** activity-based rewards permitted (BoE).

02What no framework closes

  1. Group perimeterRestrictions bind the entity, never the group: prohibited activities can be moved to a sister company. For banks, consolidated supervision closes the gap; for non-banks, nothing does. The FSI suggests some form of group-wide oversight may be needed.
  2. Multi-issuanceOne fungible token, several reserve pools. Only Singapore prohibits it outright; the UK applies its reserve rules to all fungible tokens and the BoE deems multi-issuance unfit for systemic use. Elsewhere it is unaddressed: which pool backs the claim?
  3. Deposit confusionThe UK and the US ring-fence deposit-takers; the EU does not: token liabilities sit alongside deposits. Customer confusion and contagion to the deposit franchise are left to other measures.

The upshot: counterparty analysis that stops at the issuer misses where the regulator itself locates the risk.

03The treasurer's decision: a five-test eligibility policy

Reserve quality and yield no longer settle the decision. The issuer's licence, jurisdiction and permitted perimeter determine what the holder actually owns, while redemption terms and the group perimeter are rarely analysed today.

  1. Redemption deadlineEnforceable, not merely commercial.
  2. Fees and minimumThe real cost of exiting.
  3. Reserve custodySelf-custody or third party.
  4. Group perimeterWhat sister entities do.
  5. Multi-issuanceWhich pool backs the claim.

Horizon: immediate. Formalise the eligibility policy before any operational use, not after the first internal audit question. A three-to-five-week exercise, not a programme.

Sources : BIS Financial Stability Institute, FSI Briefs No 33, August 2026; interpretation and implications: OpenbanQ analysis. For information only; not investment advice.

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