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.
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.
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.
| Jurisdiction | Regime and regulator | Position in October 2026 |
|---|---|---|
| United States | GENIUS Act; OCC, FDIC, Federal Reserve, NCUA, certified states | Law since 18 July 2025; effective by 18 January 2027; rules still proposals |
| European Union | MiCA; national regulators, EBA for significant tokens | Issuer rules in force since 30 June 2024; transitional periods ended 1 July 2026 |
| United Kingdom | Cryptoassets Regulations 2026; FCA, Bank of England for systemic coins | Final FCA rules published June 2026; window open to 28 February 2027; regime starts 25 October 2027 |
| Hong Kong | Stablecoins Ordinance (Cap. 656); HKMA | In force since 1 August 2025; first licences granted April 2026 |
| Singapore | Stablecoin framework under the Payment Services Act; MAS | Framework finalised August 2023; confirm commencement with MAS for each token |
| Japan | Payment Services Act; FSA | In force since June 2023 |
| Switzerland | Banking and AML law; FINMA | FINMA guidance of July 2024 applies; a dedicated issuer licence has been proposed |
| UAE | CBUAE, VARA, ADGM FSRA, DFSA | Payment 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.
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.
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.
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.
A public company whose business is not mainly financial needs the unanimous agreement of the Committee before it can issue.
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.
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.
| Agency | Proposal | Published |
|---|---|---|
| OCC | Full framework for issuers under OCC supervision, including non-banks | 2 March 2026 |
| FDIC | Standards for subsidiaries of FDIC-supervised banks | 10 April 2026 |
| FinCEN and OFAC | AML and sanctions programmes for permitted issuers | 10 April 2026 |
| Treasury | Issuance, offer and sale of payment stablecoins | 18 August 2026 |
| Federal Reserve | Framework for Board-supervised issuers | 29 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.
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.
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.
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.
| Feature | E-money token (EMT) | Asset-referenced token (ART) |
|---|---|---|
| Peg | One official currency, such as the euro or the dollar | A basket of currencies, commodities or other assets |
| Who may issue | A credit institution or an electronic money institution (EMI) | An authorised ART issuer established in the EU, or a credit institution |
| Permission | EMI licence plus a white paper notified to the regulator | ART authorisation, including approval of the white paper |
| Capital | EMI initial capital of €350,000 plus own funds | Highest of €350,000, 2% of average reserve assets or a quarter of fixed overheads |
| Redemption | At any time, at par, without a fee | A 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.
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.
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.
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.
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.
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.
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.
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.
The FCA published its final stablecoin issuance rules in Policy Statement PS26/10 in June 2026. They require:
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.
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.
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.
| Business model | Permission from 25 October 2027 |
|---|---|
| UK issuer | Issuing a qualifying stablecoin in the UK |
| Custodial wallet | Safeguarding qualifying cryptoassets |
| Exchange | Operating a qualifying cryptoasset trading platform |
| Broker or OTC desk | Dealing as principal or agent, or arranging deals |
| Payment firm using stablecoins for the fiat leg | Existing EMI or payment institution permission, plus a crypto permission where it holds or exchanges tokens |
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
| Model | What the business does | Licence it needs |
|---|---|---|
| Own issuer | Mints, redeems and holds reserves for its own token | Issuer authorisation in each market |
| Branded token through a licensed issuer | Markets a token that a licensed issuer mints and backs | Usually a distribution or payments permission; the issuer holds the issuer licence |
| Distributor or exchange | Lists, sells and holds third-party stablecoins for customers | Crypto service authorisation, money transmission or e-money permissions |
| Payment platform | Uses stablecoins to settle payments for clients | Payments 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.
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.
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.
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.
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.
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.
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.
| Jurisdiction | Custody permission |
|---|---|
| United States | State money transmitter licence or trust charter; under the GENIUS Act, custody only by a federally or state supervised entity |
| European Union | MiCA authorisation for custody and administration of crypto-assets |
| United Kingdom | FCA permission for safeguarding qualifying cryptoassets, with permanent minimum capital of £150,000, from 25 October 2027 |
| Hong Kong | Custody by the issuer under HKMA rules, or by an SFC-licensed platform for trading |
| Singapore | Digital payment token licence covering custody under the Payment Services Act |
| Requirement | What regulators expect |
|---|---|
| Full backing | At least 1:1 reserves in cash, deposits and short-dated government debt |
| Segregation | Reserves held on trust or in protected accounts, out of reach of the issuer's creditors |
| Reserve reporting | Monthly or quarterly public reports, with independent examination or attestation and an annual audit |
| Redemption | At par, within one to five business days depending on the regime |
| No interest | Issuers may not pay holders interest or yield |
| AML and sanctions | Customer due diligence, transaction monitoring, travel rule and sanctions screening to FATF standards |
| Technical controls | Ability to freeze and block tokens, key management, audit trails and disaster recovery |
| Governance | A board and senior team in the jurisdiction, with risk, compliance and internal audit functions |
| Capital | Own funds above the reserves, to cover operating risk and an orderly wind-down |
| Disclosure | A 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.
| Jurisdiction | Minimum 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 Kingdom | Highest of £350,000, fixed overheads requirement or 1% of coins in issue |
| Hong Kong | HK$25 million paid-up share capital |
| United States | Set by each regulator's final rule; the OCC proposal sets capital for new and existing issuers |
| Singapore | Base capital and liquid assets set by MAS |
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.
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.
| Market | Entity and permission | Capital on $100 million in circulation |
|---|---|---|
| United States | Federal qualified issuer approved by the OCC | Set by the OCC's final rule |
| European Union | EMI issuing an e-money token, passported across the EEA | Initial capital of €350,000, with own funds of 2% of average outstanding e-money, about $2 million |
| United Kingdom | FCA-authorised issuer of a qualifying stablecoin | Highest 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.
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.
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.
Across the US, the EU, the UK and Hong Kong, the files that move fastest share the same qualities:
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.
| Jurisdiction | Published or statutory standard | Planning range |
|---|---|---|
| United States | Decision within 120 days of a complete application | 4 to 6 months including preparation of the file |
| European Union (EMI) | 3 months from a complete application | 6 to 8 months after submission |
| European Union (ART) | Fixed MiCA assessment periods | 6 to 8 months after submission |
| United Kingdom | 6 months for a complete application | Window applications decided before 25 October 2027 |
| Hong Kong | No published standard | Set by the HKMA's licensing rounds |
| Singapore | No published standard | Confirm 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.
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.
| Phase | Typical timing | Focus |
|---|---|---|
| Foundation | First 6 to 12 months | First licence, reserve banking, compliance programme |
| Expansion | 12 to 24 months | Second and third regimes, reusing the core framework |
| Optimisation | 24 months and beyond | EEA 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.
Licensed issuers that run these processes well gain the bank partnerships and institutional clients that unlicensed tokens cannot reach.
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.
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.
€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.
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.
Usually yes. Custody of stablecoins and private keys is a separate permission in the US, the EU, the UK and Singapore.
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.
No. The US, EU, UK and Hong Kong regimes all prohibit issuers from paying interest or yield to holders.
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.
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.
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.