Home › Blog › stablecoins

How to Obtain a Stablecoin Licence: The Complete 2026 Guide

Published 14 October 2025 · Last reviewed 17 October 2026 · Buckingham Capital Consulting
Contents
  1. What a stablecoin licence is
  2. Global overview: where each regime stands in October 2026
  3. Choosing where to license first
  4. United States: the GENIUS Act
  5. European Union: MiCA
  6. United Kingdom: the new cryptoasset regime
  7. Hong Kong: the Stablecoins Ordinance
  8. Singapore: the MAS stablecoin framework
  9. Switzerland, the UAE and Japan
  10. Other markets
  11. Issue, partner or distribute: choosing the model
  12. Managing reserves in practice
  13. Custody licensing
  14. Requirements common to every regime
  15. Capital and costs
  16. Worked example: one dollar stablecoin in three markets
  17. Stablecoins and banking access
  18. What regulators look for in a strong application
  19. How long it takes
  20. The application process step by step
  21. Building a multi-jurisdiction structure
  22. After authorisation
  23. How Buckingham Capital Consulting helps
  24. Frequently asked questions
Key takeaways
  • There is no single stablecoin licence: the authorisation depends on where the token is issued, what it is pegged to and where it circulates, and most international issuers need two or more.
  • United States: the GENIUS Act, signed on 18 July 2025, takes effect on the earlier of 18 January 2027 or 120 days after final rules; as at October 2026 the rules are still proposals, and regulators must decide a complete application within 120 days.
  • European Union: an e-money token needs an EMI or credit institution licence (EMI initial capital €350,000) and holders can redeem at par at any time; MiCA transitional periods for service providers ended on 1 July 2026.
  • United Kingdom: issuing a qualifying stablecoin becomes an FCA-regulated activity on 25 October 2027; the application window runs from 30 September 2026 to 28 February 2027 and the permanent minimum capital is £350,000.
  • Hong Kong: the Stablecoins Ordinance has applied since 1 August 2025, requires HK$25 million paid-up capital, and the HKMA granted its first issuer licences in April 2026.
  • Every major regime requires full 1:1 backing in high-quality liquid assets, segregated reserves, redemption at par, independent reserve reporting and a ban on paying interest to holders.

What a stablecoin licence is

No regulator issues a permission called simply a stablecoin licence. The authorisation a business needs depends on three facts: where the token is issued, what it is pegged to, and where it is distributed and used. A dollar stablecoin issued from the United States, sold to European customers and used for payments in the UK can touch three separate regimes.

A stablecoin, in this guide, is a token designed to hold a stable value against a single fiat currency, such as the US dollar or the euro, backed by reserves the issuer holds. Regulators now treat these tokens as payment instruments, close to electronic money, and license their issuers in a way that resembles e-money and narrow banking: capital, reserves, redemption, audits and anti-money laundering (AML) controls.

Why a crypto registration is not enough

A virtual asset service provider registration, or a crypto exchange licence, covers trading and custody. It does not authorise issuance. A firm that issues a stablecoin to users in the US, the EU or the UK needs the issuer authorisation for that market, and the firms that distribute the token need their own permissions too.

Who this guide is for

The guide is written for founders, treasurers, compliance officers and country managers building issuance, custody, exchange or payment infrastructure around stablecoins. It sets out the position in each major jurisdiction as at October 2026, the common requirements, the costs and timelines, and how to sequence a multi-market programme.

Global overview: where each regime stands in October 2026

JurisdictionRegime and regulatorPosition in October 2026
United StatesGENIUS Act; OCC, FDIC, Federal Reserve, NCUA, certified statesLaw since 18 July 2025; effective by 18 January 2027; rules still proposals
European UnionMiCA; national regulators, EBA for significant tokensIssuer rules in force since 30 June 2024; transitional periods ended 1 July 2026
United KingdomCryptoassets Regulations 2026; FCA, Bank of England for systemic coinsFinal FCA rules published June 2026; window open to 28 February 2027; regime starts 25 October 2027
Hong KongStablecoins Ordinance (Cap. 656); HKMAIn force since 1 August 2025; first licences granted April 2026
SingaporeStablecoin framework under the Payment Services Act; MASFramework finalised August 2023; confirm commencement with MAS for each token
JapanPayment Services Act; FSAIn force since June 2023
SwitzerlandBanking and AML law; FINMAFINMA guidance of July 2024 applies; a dedicated issuer licence has been proposed
UAECBUAE, VARA, ADGM FSRA, DFSAPayment token rules for dirham tokens since 2024; free zone regimes in force

The pattern is consistent: the US, the EU, Hong Kong and Japan have regimes in force or about to take effect, the UK has final rules and an open application window, and Singapore and Switzerland have settled frameworks whose legal form is being completed.

Choosing where to license first

The first licence should match where the customers and the reserves are. A dollar stablecoin aimed at US institutions starts with the GENIUS Act. A euro stablecoin, or any token sold to EU retail customers, starts with MiCA. An Asian treasury or trade-finance product often starts in Hong Kong or Singapore.

Selection criteria

  • Market access: the customers, banks and payment networks the licence opens.
  • Legal certainty: a regime in force, with published rules and a regulator processing applications.
  • Passporting: an EU authorisation covers all 30 countries of the European Economic Area.
  • Recognition: a regime likely to be found comparable under the GENIUS Act eases later US access.
  • Operations: where the senior team, reserve banks and custodians can sit.
  • Cost and time: capital, fees and the realistic time to a decision.

Regulators converge on the same standards, so the strongest approach is to build reserves, custody and AML to the highest common standard once and apply it in each market. Choosing a jurisdiction only for a lighter rulebook tends to cost more later, when banks, institutional clients and other regulators look at the licence behind the token.

United States: the GENIUS Act

The GENIUS Act is the federal law for payment stablecoins. It was signed into law on 18 July 2025 and takes effect on the earlier of 18 January 2027 or 120 days after the federal regulators issue final rules. The rules were due by 18 July 2026; they were not finalised by that date, and as at October 2026 the OCC, FDIC, NCUA, Federal Reserve, Treasury and FinCEN with OFAC have all published proposals, none of them final. Our guide to GENIUS Act compliance covers each proposal.

Who can issue

  • Bank or credit union subsidiaries, approved by the parent's federal regulator.
  • Federal qualified issuers approved by the OCC, including non-bank companies, uninsured national banks and federal branches of foreign banks.
  • State qualified issuers with up to $10 billion outstanding, under a state regime the Stablecoin Certification Review Committee certifies as substantially similar; above $10 billion the issuer has 360 days to move to federal oversight.

A public company whose business is not mainly financial needs the unanimous agreement of the Committee before it can issue.

Core requirements

  • Reserves of at least 1:1 in cash, Federal Reserve balances, insured deposits, Treasuries with 93 days or less to maturity, overnight repos and reverse repos, government money market funds and tokenised forms of these.
  • Monthly public reserve reports, examined by a registered public accounting firm and certified by the chief executive and chief financial officer; audited annual accounts above $50 billion outstanding.
  • No interest or yield paid to holders, and a published redemption policy.
  • Bank Secrecy Act AML and sanctions programmes, and the technical ability to block, freeze and reject unlawful transactions.
  • Capital, liquidity and risk management standards set by each regulator.

Application and timeline

A regulator must decide an application within 120 days of receiving a substantially complete one, or it is treated as approved. A denial is explained in writing and can be challenged at a hearing. The steps are: choose the route, prepare the business plan, reserve framework and AML programme, hold pre-filing meetings with the regulator, file, answer questions and receive approval.

How the Act fits with state licences

Section 5(h) of the Act overrides state charter and licensing requirements for a federal qualified issuer and for an approved bank or credit union subsidiary, so these issuers need no state money transmitter licence to issue. A state qualified issuer from a certified state can serve customers in other states without a separate issuer licence in each; host-state consumer protection laws continue to apply. Each state regulator must submit its first certification to the Stablecoin Certification Review Committee no later than one year after the Act takes effect, and Treasury proposed the principles for a substantially similar state regime on 3 April 2026.

The proposals to build against

AgencyProposalPublished
OCCFull framework for issuers under OCC supervision, including non-banks2 March 2026
FDICStandards for subsidiaries of FDIC-supervised banks10 April 2026
FinCEN and OFACAML and sanctions programmes for permitted issuers10 April 2026
TreasuryIssuance, offer and sale of payment stablecoins18 August 2026
Federal ReserveFramework for Board-supervised issuers29 September 2026

The OCC proposal is the one most non-bank issuers will be licensed under, and it is the practical template for a US application file today.

Foreign issuers

A foreign issuer can serve US customers if Treasury finds its home regime comparable, it registers with the OCC, it holds enough reserves in US financial institutions to meet US redemptions, and it can comply with US lawful orders.

Distributors and payment firms

From 18 July 2028, exchanges, wallets and other digital asset service providers may offer or sell only permitted stablecoins to people in the United States. These intermediaries still need FinCEN money services business registration and state money transmitter licences, explained in our guide to the US money transmitter licence for stablecoin companies.

European Union: MiCA

The Markets in Crypto-Assets Regulation (MiCA) sets one rulebook for the European Economic Area. Its rules for stablecoin issuers have applied since 30 June 2024, and its rules for crypto-asset service providers since 30 December 2024. The national transitional periods for existing service providers ended on 1 July 2026 at the latest in every member state, so any firm offering crypto services in the EU now needs a MiCA authorisation.

E-money tokens and asset-referenced tokens

FeatureE-money token (EMT)Asset-referenced token (ART)
PegOne official currency, such as the euro or the dollarA basket of currencies, commodities or other assets
Who may issueA credit institution or an electronic money institution (EMI)An authorised ART issuer established in the EU, or a credit institution
PermissionEMI licence plus a white paper notified to the regulatorART authorisation, including approval of the white paper
CapitalEMI initial capital of €350,000 plus own fundsHighest of €350,000, 2% of average reserve assets or a quarter of fixed overheads
RedemptionAt any time, at par, without a feeA permanent right of redemption against the issuer

Most dollar and euro stablecoins are e-money tokens, so for most issuers the route is an EMI licence. The firm prepares MiCA stablecoin licence applications for both types.

Reserve and conduct rules

  • At least 30% of the funds received for an EMT must be held in deposits at credit institutions, with the balance in secure, highly liquid instruments in the same currency; the share is higher for significant tokens.
  • No interest may be paid to holders of either type of token.
  • The white paper must be published before the offer, and an EMT white paper is notified to the home regulator at least 20 working days before publication.
  • Issuers keep a recovery plan and a redemption plan, governance and conflict-of-interest arrangements, and a complaints procedure.
  • Digital operational resilience rules under DORA apply.

Significant tokens and usage limits

A token can be classified as significant when it passes thresholds set in MiCA, such as a value above €5 billion. Significant tokens come under the European Banking Authority's supervision and face higher capital and liquidity requirements. An ART, or an EMT in a non-EU currency, used widely as a means of exchange in a single currency area, above 1 million transactions or €200 million a day, must stop new issuance until it falls back below that level.

Distributors and payment services

Crypto-asset service providers in the EU may offer only tokens whose issuers are authorised under MiCA. Where a service provider carries out payment services with e-money tokens, the European Banking Authority has said that a payment services authorisation under PSD2 is also needed. Its transition for this ended on 2 March 2026, and its Opinion of 12 February 2026 sets the conditions on which firms with pending applications may continue.

Application and timeline

The applicant chooses a home member state and applies to its national regulator, then passports across the EEA. An EMI licence follows the e-money and payment services directives; the firm plans EMI authorisations at 6 to 8 months after submission. ART authorisation follows MiCA's fixed assessment periods and runs to a similar overall time from a complete file.

Choosing a home member state

The rulebook is the same everywhere, so the choice of home state turns on the regulator's experience with e-money and crypto files, the language of supervision, access to euro banking for reserves, and where the senior team will live. The firm's guide to choosing an EU jurisdiction for an EMI licence compares the main regulators; the decision should be made with the reserve banks and custodians already identified, because the regulator will ask for them.

What the application contains

  • A programme of operations describing the token, the distribution model and three years of financial projections.
  • Governance arrangements, the management body's experience and the fitness and propriety of directors and qualifying shareholders.
  • The reserve policy: composition, custody, segregation, liquidity management and stress testing.
  • The redemption plan and the recovery plan required by MiCA.
  • AML and counter-terrorist financing policies, including the travel rule for crypto-asset transfers.
  • ICT and security arrangements meeting DORA, with business continuity and incident reporting.
  • The crypto-asset white paper, and for an ART a legal opinion that the token falls within the ART definition.

After the transitional periods

Since 1 July 2026 no firm in the EU can rely on a national registration for crypto services. Exchanges and wallets must have MiCA authorisation, and they may list for EU customers only stablecoins whose issuers are authorised under MiCA. Tokens from unauthorised issuers have been removed from EU retail offerings or limited to sale-only.

Penalties

Member states can impose fines on issuers of up to €15 million or 3% of annual turnover, ban individuals from management roles and withdraw authorisation.

United Kingdom: the new cryptoasset regime

The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (SI 2026/102), made on 4 February 2026, create a new regulated activity of issuing a qualifying stablecoin in the UK. From 25 October 2027 a firm needs FCA permission under Part 4A of the Financial Services and Markets Act 2000 to carry it on. The FCA's application window opened on 30 September 2026 and closes on 28 February 2027. Our page on UK cryptoasset authorisation covers the full regime.

Final rules for issuers (PS26/10)

The FCA published its final stablecoin issuance rules in Policy Statement PS26/10 in June 2026. They require:

  • Full backing for every token minted, in the stablecoin's reference currency, held on a statutory trust for holders, with a separate trust for each stablecoin.
  • A liquid core: a share of backing assets in on-demand bank deposits and core backing assets, set at the higher of a 5% floor or the largest daily redemption over the previous 180 redemption days.
  • Redemption at par by the end of the next business day after the issuer receives the token, for any amount.
  • Custody under CASS 16: a signed acknowledgement letter from each custodian, daily internal and external reconciliations, and no more than 20% of the backing pool with group custodians unless justified.
  • Disclosures on the website, with backing and circulation data updated at least every three months and an annual independent review of the 1:1 backing.
  • No interest or income from the backing pool passed to holders, directly or through third parties.

Capital (PS26/12)

A UK stablecoin issuer holds own funds of at least the highest of a permanent minimum requirement of £350,000, its fixed overheads requirement, and a K-factor charge of 1% of the value of coins in issue.

Systemic stablecoins and payments

Stablecoins that HM Treasury recognises as systemic, because they are widely used for payments, come under joint supervision by the Bank of England and the FCA. The Bank has consulted on its regime for sterling systemic stablecoins, including temporary limits on holdings, and its final rules should be checked before a systemic launch. Using stablecoins for payments raises separate questions about e-money and payment services permissions, covered in our guide to stablecoin payments regulation in the UK.

Overseas stablecoins

The issuance permission covers issuing in the UK. An overseas-issued stablecoin can still be traded and held in the UK through FCA-authorised platforms and custodians, which carry the regulatory duties for their own activities.

What the FCA application contains

  • A regulatory business plan that matches the permissions sought, with the issuance model, distribution and revenue.
  • The people: board, chief executive, compliance officer and MLRO approved under the senior managers regime, with clear responsibilities.
  • The financial case: three-year forecasts, capital and liquidity calculations, stress tests and a wind-down plan.
  • The backing asset policy, trust arrangements, custodian acknowledgement letters and reconciliation process under CASS 16.
  • The redemption process, with evidence it can meet the next-business-day standard at scale.
  • Financial crime controls: business-wide risk assessment, customer due diligence, blockchain analytics and sanctions screening.
  • Consumer Duty assessment, holder disclosures and complaints handling.

Which UK permissions a stablecoin business needs

Business modelPermission from 25 October 2027
UK issuerIssuing a qualifying stablecoin in the UK
Custodial walletSafeguarding qualifying cryptoassets
ExchangeOperating a qualifying cryptoasset trading platform
Broker or OTC deskDealing as principal or agent, or arranging deals
Payment firm using stablecoins for the fiat legExisting EMI or payment institution permission, plus a crypto permission where it holds or exchanges tokens

Timeline

The FCA will review window applications in the order received and aims to decide them before 25 October 2027. Its statutory limit for a complete application is six months. An existing MLR-registered firm that applies in the window and is still awaiting a decision at commencement can continue its existing activities while the FCA decides.

Hong Kong: the Stablecoins Ordinance

The Stablecoins Ordinance (Cap. 656) took effect on 1 August 2025. The Hong Kong Monetary Authority (HKMA) licenses issuers of fiat-referenced stablecoins and granted its first issuer licences in April 2026. Licensed issuers are listed on the HKMA's public register.

Who needs a licence

  • Any person issuing a fiat-referenced stablecoin in Hong Kong.
  • Any person issuing, anywhere, a stablecoin that references the Hong Kong dollar.
  • Any person actively marketing the issue of a fiat-referenced stablecoin to the Hong Kong public.

Only stablecoins issued by licensed issuers may be offered to retail investors in Hong Kong, and only by permitted offerors such as licensed banks and licensed trading platforms.

Requirements

  • A company incorporated in Hong Kong, or an authorised institution under the Banking Ordinance.
  • Minimum paid-up share capital of HK$25 million, plus liquid capital and resources to cover operating costs.
  • Reserves at full value at all times, segregated from the issuer's own assets and held on trust for holders.
  • Redemption at par, in a timely way, without unreasonable conditions or fees.
  • No interest paid to holders.
  • Chief executive, senior management and key staff based in Hong Kong and fit and proper.
  • AML and sanctions controls, and published disclosures on reserves and redemption.

Ongoing duties

  • Regular publication of the reserve composition and market value, with periodic independent attestation.
  • A published white paper describing the stablecoin, the reserve arrangements and holders' rights.
  • Prompt reporting to the HKMA of material events, including any shortfall in reserves.
  • Ongoing fitness and propriety of controllers, directors and stablecoin managers.

It is an offence to describe a token as a licensed stablecoin when its issuer is not licensed, and a licensed issuer's reserves are protected for holders if the issuer becomes insolvent.

Applying

The HKMA asks applicants to engage early and to submit a complete file with an independent assessment of their systems and controls. It publishes no fixed service standard, and it has signalled that it will license a small number of issuers at first, so a strong business case and a Hong Kong team matter as much as the documents.

Singapore: the MAS stablecoin framework

The Monetary Authority of Singapore (MAS) finalised its stablecoin framework on 15 August 2023. It applies to single-currency stablecoins pegged to the Singapore dollar or a G10 currency and issued in Singapore, and it is implemented through the Payment Services Act. An issuer should confirm the current commencement position with MAS for its token before filing.

Requirements

  • Reserve assets valued at least at the stablecoins in circulation, held separately with approved custodians, with independent monthly attestations and an annual audit.
  • Minimum base capital and liquid assets set by MAS, sized to allow an orderly wind-down.
  • Redemption at par within five business days of a request.
  • A white paper disclosing the value-stabilising mechanism, holders' rights and reserve audit results.

Only tokens that meet every requirement may carry the label "MAS-regulated stablecoin", and misusing the label is an offence. Smaller issuers below the MAS threshold may operate outside the full regime but cannot use the label. Exchanges and wallets that deal in stablecoins in Singapore need a digital payment token licence under the Payment Services Act.

Switzerland, the UAE and Japan

Switzerland

FINMA applies existing banking and AML law to stablecoins. Its guidance 06/2024 of July 2024 explains that an issuer which takes in customer funds may need a banking licence, unless a bank guarantees holders' claims in full, and that holders must be identified. The Federal Council has proposed a dedicated licence for stablecoin issuers; until it is enacted, FINMA's guidance sets the position.

United Arab Emirates

The Central Bank of the UAE regulates payment tokens under its Payment Token Services Regulation of 2024: issuing a dirham-backed payment token for use in the UAE needs a Central Bank licence, and foreign payment tokens may be used only in limited cases, such as buying virtual assets. In Dubai, VARA licenses the issuance of fiat-referenced virtual assets. The financial free zones run their own regimes: the ADGM Financial Services Regulatory Authority for fiat-referenced tokens in Abu Dhabi Global Market, and the DFSA in the Dubai International Financial Centre, which recognises tokens before they can be used there.

Japan

Amendments to the Payment Services Act in force since June 2023 treat fiat-backed stablecoins as electronic payment instruments. Only banks, registered fund transfer service providers and trust companies may issue them, and firms that exchange or transfer them for customers need registration with the Financial Services Agency as electronic payment instruments service providers. Japan was the first major economy to put a stablecoin issuer regime into force, and its approach of limiting issuance to banks, fund transfer providers and trust companies is the closest to a banking model of any regime in this guide.

Other markets

  • Canada: the federal government announced a federal stablecoin framework in Budget 2025, with the Bank of Canada supervising issuers. Firms should confirm its commencement before planning; dealers in virtual currency already register with FINTRAC as money services businesses.
  • Australia: payment stablecoins are being brought into the reformed payments licensing framework as a form of stored-value facility, with ASIC as regulator. AUSTRAC's reforms for remittance and virtual asset businesses took effect on 31 March 2026.
  • Brazil: Banco Central do Brasil's rules for virtual asset service providers, published in November 2025, require authorisation for firms providing virtual asset services and treat cross-border stablecoin payments as foreign exchange operations.
  • South Korea: legislation for won-denominated stablecoins is in progress; dealers already register with the Korea Financial Intelligence Unit.

In each of these markets the issuer regime is newer than in the US, the EU or Hong Kong, so a global issuer usually enters them through local partners or licensed distributors first.

Issue, partner or distribute: choosing the model

Not every business that wants a stablecoin needs to become an issuer. The licence follows the role, so the first decision is which role the business will play.

ModelWhat the business doesLicence it needs
Own issuerMints, redeems and holds reserves for its own tokenIssuer authorisation in each market
Branded token through a licensed issuerMarkets a token that a licensed issuer mints and backsUsually a distribution or payments permission; the issuer holds the issuer licence
Distributor or exchangeLists, sells and holds third-party stablecoins for customersCrypto service authorisation, money transmission or e-money permissions
Payment platformUses stablecoins to settle payments for clientsPayments or money transmission licences, plus custody where it holds tokens

An own-issuer licence gives control of the reserve income and the brand, at the cost of capital, a full compliance function and supervision as a financial institution. A branded token through a licensed issuer reaches the market faster and shares the reserve income with the issuer. A business that expects to hold large balances in circulation over several years usually moves from the second model to the first once volumes justify the capital.

Under every model the business still needs the right permission for what it does with customers' money and tokens. Using a licensed issuer moves the issuer duties to that issuer; it does not remove the distributor's own licensing, AML and custody duties.

Managing reserves in practice

Reserves are where regulators spend most of their review time, because the holder's protection depends on them. A strong reserve framework answers four questions: what the reserves are, where they are held, how they are reconciled and how quickly they can be turned into cash.

Composition

Every regime limits reserves to cash, bank deposits and short-dated government debt, and most require a liquid core in on-demand deposits. The board-approved reserve policy should set target ranges for each asset type, maximum maturities, and limits per bank and per custodian, so that no single counterparty holds a large share of the reserves.

Custody and segregation

Reserves are held in accounts named for the benefit of holders, on trust or under a statutory protection, with written acknowledgements from each bank and custodian that the funds are not available to the issuer's creditors. Group custodians are limited in some regimes, for example to 20% of the backing pool in the UK.

Reconciliation

Tokens in circulation on every blockchain the token runs on are reconciled to the reserve balances every day, and any difference is investigated and resolved the same day. The reconciliation records are the evidence the independent accountant tests for the monthly report.

Liquidity and redemption

The issuer models redemptions under stress, such as a fall in confidence or the loss of a banking partner, and holds enough same-day liquidity to meet the largest plausible outflow within the regime's redemption deadline: the next business day in the UK, one business day in Hong Kong and five in Singapore.

Custody licensing

Holding stablecoins, private keys or reserves for others is regulated separately from issuance in almost every market. A business that issues and also runs custodial wallets for its customers usually needs both permissions, often in separate entities.

JurisdictionCustody permission
United StatesState money transmitter licence or trust charter; under the GENIUS Act, custody only by a federally or state supervised entity
European UnionMiCA authorisation for custody and administration of crypto-assets
United KingdomFCA permission for safeguarding qualifying cryptoassets, with permanent minimum capital of £150,000, from 25 October 2027
Hong KongCustody by the issuer under HKMA rules, or by an SFC-licensed platform for trading
SingaporeDigital payment token licence covering custody under the Payment Services Act

What custody regulators look for

  • Private key management with multi-party approval and secure storage.
  • Segregation of client assets from the firm's own, with no commingling or reuse.
  • Daily reconciliation of on-chain holdings to client records.
  • Cybersecurity, operational resilience and tested incident response.
  • Insurance or financial resources sized to the assets held, and a wind-down plan.

Requirements common to every regime

RequirementWhat regulators expect
Full backingAt least 1:1 reserves in cash, deposits and short-dated government debt
SegregationReserves held on trust or in protected accounts, out of reach of the issuer's creditors
Reserve reportingMonthly or quarterly public reports, with independent examination or attestation and an annual audit
RedemptionAt par, within one to five business days depending on the regime
No interestIssuers may not pay holders interest or yield
AML and sanctionsCustomer due diligence, transaction monitoring, travel rule and sanctions screening to FATF standards
Technical controlsAbility to freeze and block tokens, key management, audit trails and disaster recovery
GovernanceA board and senior team in the jurisdiction, with risk, compliance and internal audit functions
CapitalOwn funds above the reserves, to cover operating risk and an orderly wind-down
DisclosureA white paper or public disclosures on reserves, rights and risks

Algorithmic stablecoins, which hold their value through trading mechanisms rather than reserves, cannot be authorised under any of these regimes and may not be marketed as stablecoins in most of them.

Capital and costs

Minimum capital

JurisdictionMinimum capital for an issuer
European Union (EMT through an EMI)€350,000 initial capital, plus own funds that rise with tokens in issue
European Union (ART)Highest of €350,000, 2% of average reserve assets or a quarter of fixed overheads
United KingdomHighest of £350,000, fixed overheads requirement or 1% of coins in issue
Hong KongHK$25 million paid-up share capital
United StatesSet by each regulator's final rule; the OCC proposal sets capital for new and existing issuers
SingaporeBase capital and liquid assets set by MAS

Budget lines

  • Regulator fees: for example, the FCA charges £5,640 to apply as an authorised EMI, and the New York BitLicense fee is $5,000.
  • Professional support for the business plan, reserve framework, policies and regulator meetings.
  • Monthly reserve examinations or attestations and the annual audit by an independent accounting firm.
  • Compliance technology: blockchain analytics, transaction monitoring, customer due diligence and travel rule tools.
  • Custody, banking and the technology for minting, redemption and freezing.
  • Compliance staff, including a chief compliance officer and an MLRO in each licensed entity.

Excluding capital, a first-year budget per jurisdiction commonly runs from several hundred thousand dollars to more than one million, depending on scale and on how much infrastructure is shared between entities.

Worked example: one dollar stablecoin in three markets

Consider an issuer planning a dollar stablecoin with $100 million in circulation in each of the US, the EU and the UK. It needs three issuing entities, each holding its own reserves and capital.

MarketEntity and permissionCapital on $100 million in circulation
United StatesFederal qualified issuer approved by the OCCSet by the OCC's final rule
European UnionEMI issuing an e-money token, passported across the EEAInitial capital of €350,000, with own funds of 2% of average outstanding e-money, about $2 million
United KingdomFCA-authorised issuer of a qualifying stablecoinHighest of £350,000, the fixed overheads requirement and 1% of coins in issue, about $1 million

Each entity also holds $100 million of reserves, which are not capital: they belong to holders. The EU entity keeps at least 30% of the funds received in bank deposits; the UK entity keeps a liquid core of at least 5% in on-demand deposits and core backing assets; the US entity holds only the assets the GENIUS Act lists. Redemption runs to each regime's standard: at par at any time in the EU, by the next business day in the UK, and under the published policy in the US.

The three entities can share a single technology platform, one analytics provider, one group AML framework and the same custodians where each regulator accepts them. That shared core is what makes a three-market programme affordable: the second and third applications reuse most of the first file, adapted to each regulator's rules. A US-first issuer that later adds the EU usually finds that its reserve and AML frameworks need only modest changes, while its group structure, capital and local team need the most planning.

Stablecoins and banking access

Every stablecoin depends on banks: for reserve accounts, for the issuer's operating accounts, and for the dollars, euros or pounds that customers pay in and take out. Banks review a stablecoin issuer as a financial institution client and look for the same evidence as a regulator.

  • An issuer licence, or a credible application under review, in the bank's own jurisdiction.
  • Reserve accounts titled for the benefit of holders and kept separate from operating funds.
  • An AML programme with blockchain analytics, sanctions screening and a named MLRO.
  • Clear information on which customers can mint and redeem directly, and in which countries.
  • Monthly reserve reports and an audited balance sheet.

Spreading reserves across several banks reduces concentration and meets the counterparty limits that several regimes impose. Issuers that open banking discussions while the licence application is being prepared, rather than after approval, launch sooner.

What regulators look for in a strong application

Across the US, the EU, the UK and Hong Kong, the files that move fastest share the same qualities:

  • One consistent story: the business plan, white paper, financial model, policies and customer terms describe the same token, flows and entities.
  • Named counterparties: reserve banks, custodians, auditors and analytics providers identified, with signed or near-final agreements.
  • A team on the ground: senior managers in the jurisdiction with relevant payments, treasury or banking experience, not only crypto experience.
  • Tested technology: independent security reviews of the smart contracts and of the freezing and minting controls.
  • Realistic projections: growth, revenue from reserves and costs that a regulator can recognise, with a stress case and a wind-down plan.
  • Clear redemption: an explanation, step by step, of how a holder redeems and how quickly the money arrives.

Regulators also look for applicants that are open about what is not yet in place. A file that lists open items, with owners and dates, is treated as more credible than one that presents every control as finished.

How long it takes

JurisdictionPublished or statutory standardPlanning range
United StatesDecision within 120 days of a complete application4 to 6 months including preparation of the file
European Union (EMI)3 months from a complete application6 to 8 months after submission
European Union (ART)Fixed MiCA assessment periods6 to 8 months after submission
United Kingdom6 months for a complete applicationWindow applications decided before 25 October 2027
Hong KongNo published standardSet by the HKMA's licensing rounds
SingaporeNo published standardConfirm with MAS

Preparation usually takes two to four months before filing. The complete, consistent file is the main driver of speed in every regime: a regulator that receives a full reserve framework, AML programme and financial model on day one decides fastest.

The application process step by step

  1. Gap analysis: map the token, the issuing entity, the reserves and the distribution channels against each target regime.
  2. Structure: decide which entity issues for which market, where reserves are held, and which entity provides custody.
  3. Team: appoint the board, chief executive, compliance officer and MLRO in the jurisdiction, with relevant experience.
  4. Reserve and custody arrangements: open reserve accounts and custody agreements with eligible banks and custodians.
  5. Technology: build minting, redemption, freezing and reconciliation systems, with independent security testing.
  6. Documents: business plan, financial projections, white paper, policies and the AML programme, all describing the same business.
  7. Regulator engagement: pre-application meetings to agree the scope and expectations.
  8. Filing and review: submit a complete file, answer questions promptly and keep the regulator informed of any change.

Building a multi-jurisdiction structure

An issuer with ambitions in several markets usually needs more than one authorisation, and the structure should be designed for that from the start. A dollar stablecoin distributed to EU users triggers MiCA and needs an EU EMI. The same token reaching US persons triggers the GENIUS Act and needs a permitted issuer. These are separate tracks, often held by separate group entities, but reserves, custody and operations can serve both if they are built to the stricter standard in each area.

A phased plan

PhaseTypical timingFocus
FoundationFirst 6 to 12 monthsFirst licence, reserve banking, compliance programme
Expansion12 to 24 monthsSecond and third regimes, reusing the core framework
Optimisation24 months and beyondEEA passporting, recognition and distribution partners

Designing for one market and adding others later typically forces a restructuring of the issuing entity and its reserves. Planning both from the outset is cheaper and faster.

After authorisation

  • Daily reconciliation of tokens in circulation to reserves.
  • Monthly or quarterly reserve reports and attestations, and the annual audit.
  • Ongoing AML monitoring, sanctions screening and suspicious activity reporting.
  • Regulatory returns, supervisory meetings and notification of material changes.
  • Annual testing of business continuity, cybersecurity and wind-down plans.
  • Training for staff and board, and a process for tracking rule changes in every market.

Licensed issuers that run these processes well gain the bank partnerships and institutional clients that unlicensed tokens cannot reach.

How Buckingham Capital Consulting helps

  • Strategy: which regime to enter first, and the group structure for issuance, custody and distribution.
  • Applications: EMI and MiCA, FCA, GENIUS Act and other filings, prepared and managed through review.
  • Reserves and custody: reserve policy, trust and custody arrangements, and the reporting process.
  • Compliance: AML, sanctions and blockchain analytics programmes, and governance.
  • Ongoing support: returns, supervisory reviews and changes as the rules develop.

EU issuers can combine this with MiCA authorisation for custody and exchange activities in the same group, so that issuance and distribution are licensed together.

Frequently asked questions

How long does it take to obtain a stablecoin licence?

In the US a regulator must decide within 120 days of a complete application. The firm plans EU EMI authorisations at 6 to 8 months after submission, and the FCA aims to decide UK window applications before 25 October 2027.

What is the minimum capital for a stablecoin issuer?

€350,000 for an EU EMI issuing e-money tokens, £350,000 or more in the UK, and HK$25 million paid-up capital in Hong Kong. US capital will be set by the final GENIUS Act rules.

Can one licence cover several countries?

Only in the EU, where a MiCA or EMI authorisation passports across the European Economic Area. Elsewhere each market needs its own authorisation, though a strong first licence supports later applications.

Do I need separate licences for issuance and custody?

Usually yes. Custody of stablecoins and private keys is a separate permission in the US, the EU, the UK and Singapore.

Can foreign issuers serve US customers?

Yes, if Treasury finds their home regime comparable, they register with the OCC, hold enough reserves in US institutions and can comply with US lawful orders.

Can stablecoins pay interest to holders?

No. The US, EU, UK and Hong Kong regimes all prohibit issuers from paying interest or yield to holders.

What is the difference between an EMT and an ART?

An EMT is pegged to one official currency and is issued by an EMI or bank. An ART is pegged to a basket of assets and needs a separate MiCA authorisation.

Can an algorithmic stablecoin be licensed?

No. Every major regime requires full reserve backing, so a token that relies on trading mechanisms to hold its value cannot be authorised as a stablecoin.

References

  1. GENIUS Act, Public Law 119-27 (GovInfo)
  2. OCC proposed rule implementing the GENIUS Act, Federal Register, 2 March 2026
  3. Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA), EUR-Lex
  4. EBA Opinion on the end of the transition under its No Action Letter on PSD2 and MiCA, 12 February 2026
  5. The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (SI 2026/102)
  6. FCA PS26/10: Crypto regime, stablecoin issuance
  7. HKMA: Stablecoin issuers
  8. MAS finalises stablecoin regulatory framework, 15 August 2023

About Buckingham Capital Consulting

Buckingham Capital Consulting has obtained e-money and payment licences since 2013 for firms including Dzing Finance, Hryze and HFS with the FCA and Own Solutions with the Central Bank of Ireland, the EMI route that EU e-money token issuers use under MiCA. The firm prepares stablecoin issuer applications across the EU, the UK, the US and Asia, and builds the reserve, custody and AML frameworks each regulator reviews.

Speak to an expert: WhatsApp +44 7563 115980, Telegram @buckinghamcapital or info@buckinghamcapitalconsulting.co.uk.

This article is general information, reviewed against the regulator’s published requirements on the date shown. It is not legal advice; the regulator’s current publications take precedence.