This document provides side-by-side comparison tables across ten regulatory dimensions for all 18 jurisdictions studied in this research project. Each table synthesises data from the individual country regulation files in Americas, Europe, Asia-Pacific, and Middle East & Africa regions, as well as from the guidance documents on issuance licensing, reserves, redemption rights, AML/KYC, taxation, algorithmic stablecoins, systemic risk, payment integration, and international standards.
Cells marked "Not verified" indicate that no verified information was found in the source files. Cells marked "N/A" indicate the dimension does not apply to that jurisdiction. Abbreviations are defined at the end of the document.
Table 1: Legal Status and Institutional Design
This table captures how each jurisdiction classifies stablecoins legally and which agencies hold primary and secondary regulatory authority. For detailed country-level analysis, see individual regulation files linked from United States, European Union, and other country pages.
| Country | Legal Status | Primary Regulator | Secondary Regulator | Key Statute | Effective Date | License Type |
|---|---|---|---|---|---|---|
| United States | Payment stablecoins neither securities nor commodities (GENIUS Act) | OCC (nonbank PPSIs); Fed/FDIC/NCUA (bank/CU subsidiaries) | FinCEN (AML/BSA); SEC/CFTC (non-compliant/algorithmic); state regulators (NYDFS, Wyoming) | GENIUS Act (S.1582) | Enacted Jul 18 2025; effective earlier of Jan 18 2027 or 120 days after final rules (no final rule as of Jun 2026) | PPSI: bank subsidiary, nonbank federal (OCC), or state-qualified |
| Canada | Value-Referenced Crypto Asset (VRCA); may be securities/derivatives; CRA treats as commodity | CSA / provincial commissions; Bank of Canada (Stablecoin Act, pending in-force) | FINTRAC (AML); Dept. of Finance; CRA (tax) | CSA Staff Notices 21-332/21-333; Stablecoin Act (Division 45, Bill C-15) | Stablecoin Act received Royal Assent 26 Mar 2026 — law but NOT yet in force (in-force date by Order in Council); framework anticipated 2027 | Federal: Bank of Canada registry inclusion; Provincial: CTP listing via issuer undertaking |
| Brazil | Virtual assets (Law 14,478/2022); FRS transactions classified as FX operations (Res. 521) | Central Bank of Brazil (BCB) | CVM (securities-like tokens); Receita Federal (tax) | Law 14,478/2022; BCB Res. 519/520/521/2025; Instruction 701/2026; Res. 561/2026 | Law effective 20 Jun 2023; BCB resolution framework effective 2 Feb 2026 | SPSAV authorisation |
| Bermuda | Digital assets under DABA; fiat-redeemable stablecoins recognised as distinct payment-instrument risk profile | Bermuda Monetary Authority (BMA) — sole authority | Financial Intelligence Agency (FIA) for AML reporting | DABA 2018; SCPS Guidance (Nov 2024); proposed Payment Services Act | DABA enacted 2018; SCPS Guidance finalised Nov 2024 | DABA licence (Class T/M/F) plus SCPS compliance for SCPSIs |
| EU | EMTs (single official currency) and ARTs (other value/basket) under MiCA Art 3 | National Competent Authorities; ESMA and EBA (EBA direct supervision for significant tokens) | ECB and national central banks consulted in significance assessment | Regulation (EU) 2023/1114 (MiCA), Titles III (ARTs) and IV (EMTs) | MiCA in force 29 Jun 2023; stablecoin provisions applicable from 30 Jun 2024 (enacted and applicable) | EMT: credit institution or EMI authorisation + white paper; ART: Article 21 authorisation |
| United Kingdom | "Qualifying stablecoin" — cryptoasset referencing fiat value via issuer holding fiat (or fiat + other assets) | Financial Conduct Authority (FCA) | Bank of England (systemic); HMT designates | FSMA 2023; The FSMA 2000 (Cryptoassets) Regulations 2026 (made 4 Feb 2026); CP25/14 | Regulations made 4 Feb 2026; full regime commences 25 Oct 2027 (prospective) | FCA authorisation as authorised cryptoasset firm; BoE systemic recognition layer |
| Switzerland | Integrated into existing financial market law; fiat-backed stablecoins typically payment tokens triggering deposit-taking regulation | Swiss Financial Market Supervisory Authority (FINMA) | SROs (AML); Swiss National Bank; Swiss Federal Tax Administration | Banking Act & Ordinance; DLT Act (1 Aug 2021); AMLA; FMIA; FinIA; FINMA Guidance 06/2024 | DLT Act in force 1 Aug 2021; FINMA Guidance 06/2024 published 26 Jul 2024; FinIA amendments proposed (consultation closed 6 Feb 2026, not enacted) | Full banking licence, FinTech licence (Art 1b BankA), or default-guarantee exemption; proposed Payment Institution licence under FinIA |
| Turkey | Crypto assets as independent digital property; stablecoins a subset (no separate category) | Capital Markets Board (CMB/SPK) | MASAK (AML/CFT); CBRT (payment ban); BDDK; Revenue Administration | Law No. 7518; CMB Communiqués III-35/B.1 & III-35/B.2; MASAK Circular No. 29 | Law No. 7518 published 2 Jul 2024; Communiqués 13 Mar 2025 | CASP licence (platform/custody) — no dedicated stablecoin issuance licence |
| Japan | Fiat-backed, par-redeemable stablecoins classified as Electronic Payment Instruments (EPIs) under PSA Art. 2(5); four EPI sub-types | Financial Services Agency (JFSA) | Kanto Local Finance Bureau; JVCEA (SRO); JAFIC (STR); Bank of Japan (CBDC research) | Payment Services Act (Act No. 59 of 2009, amended 2022 and 2025); Banking Act; Trust Business Act; APTCP | EPI framework effective 1 Jun 2023; PSA Amendment Act 2025 enacted 6 Jun 2025, takes effect 1 Jun 2026 | Bank licence / fund transfer registration / trust company licence (issuers); EPIESP registration (intermediaries) |
| Singapore | Digital Payment Token (DPT) under PSA; privileged MAS-regulated Single-Currency Stablecoin (SCS) designation; intangible property for tax | Monetary Authority of Singapore (MAS) | Inland Revenue Authority of Singapore (IRAS) for tax | Payment Services Act 2019; SCS Framework (MAS policy 15 Aug 2023); FSMA 2022 Part 9 (DTSP) | PSA in force, amended 4 Apr 2024; SCS framework policy finalised 15 Aug 2023; SCS legislative amendments NOT yet enacted (expected mid-2026) | Major Payment Institution licence + SCS designation; DTSP licence for overseas services |
| Hong Kong | Dedicated regime for fiat-referenced stablecoins (FRS); enacted, in force, and issuing licences | Hong Kong Monetary Authority (HKMA) | Securities and Futures Commission (SFC) — VASP/VATP oversight under AMLO | Stablecoins Ordinance (Cap. 656) | Passed 21 May 2025; gazetted 30 May 2025; effective 1 Aug 2025; first licences granted 10 Apr 2026 | HKMA stablecoin issuer licence (FRS) |
| South Korea | No stablecoin-specific law enacted; VAUPA provides baseline; DABA would classify stablecoins as "asset-linked digital assets" (pending bill) | Financial Services Commission (FSC) | Bank of Korea (BOK); Korea Financial Intelligence Unit (KoFIU) | Virtual Asset Users Protection Act (VAUPA); Digital Asset Basic Act (DABA) — pending bill | VAUPA effective 19 Jul 2024; DABA introduced 10 Jun 2025 but NOT passed (review pushed to H2 2026) | No operational stablecoin licence; DABA proposes FSC authorisation regime (pending) |
| Australia | Stablecoins are "financial products" (non-cash payment facilities); confirmed by ASIC INFO 225 (29 Oct 2025); no dedicated statute yet | ASIC (existing law); APRA (proposed prudential under Tranche 1) | Treasury (legislative reform); AUSTRAC (AML) | Corporations Act 2001; proposed Payment Entities (Prudential Regulation) Bill 2026 + Payments System Modernisation Bill 2026 (exposure draft) | AFSL/INFO 225 regime current; Tranche 1 PSP package in exposure draft (released 12 Mar 2026, consultation closed 9 Apr 2026) — NOT enacted | AFSL; proposed APRA registration for major SVF/currency stablecoin issuers |
| India | No dedicated legislation; stablecoins classified as Virtual Digital Assets (VDAs) under s.2(47A) Income Tax Act 1961; RBI opposes private stablecoins | Reserve Bank of India (RBI) | Ministry of Finance / CBDT (tax); FIU-IND (AML); SEBI (potential future) | Income Tax Act 1961 (Sec 2(47A), 115BBH); Finance Act 2022; PMLA 2002; FEMA 1999 | VDA tax classification from Finance Act 2022; no stablecoin statute (proposed COINS Act 2025/CARA not enacted) | None — no stablecoin issuance licensing regime |
| UAE | Hybrid — Payment Tokens (CBUAE), Fiat-Referenced Tokens (ADGM/FSRA), FRVAs (VARA); AED-pegged exclusively CBUAE; not legal tender | CBUAE (federal; dirham/payment tokens) + VARA (Dubai) + FSRA/ADGM + DFSA/DIFC + CMA (formerly SCA) | Five-authority model (CBUAE, VARA, FSRA/ADGM, DFSA/DIFC, CMA) | CBUAE PTSR; VARA Issuance Rulebook v2.0; ADGM FRT framework; Federal Decree Law No. 6 of 2025; CMA Decision No. 4/R.M/2026 | PTSR issued 7 Jun 2024, effective 6 Jul 2024 | CBUAE Licensed Payment Token Issuer; VARA Category 1 FRVA licence; ADGM FSRA FRT permission; DFSA-approved Fiat Crypto Token |
| Bahrain | Stablecoins a subset of crypto-assets (not legal tender); only single-currency fiat-backed permitted | Central Bank of Bahrain (CBB) | None (single-authority model) | CRA Module (Feb 2019); Stablecoin Issuance and Offering (SIO) Module | SIO Module issued and effective 2 Jul 2025 | Dedicated SIO Module stablecoin issuer licence (separate from CRA Module CASP licences) |
| South Africa | Crypto-assets are financial products under FAIS Act (2022); stablecoins in a regulatory grey area; not legal tender | Financial Sector Conduct Authority (FSCA) | Prudential Authority (PA); SARB; FIC; SARS; IFWG (coordination) | FAIS Act 2002 + FSCA Declaration (2022); FICA; draft CFM Regulations 2026; SARB/FSCA Joint Communication (May 2026) | FSCA FAIS Declaration effective 19 Dec 2022 | CASP licence (FSP under FAIS Act) — advisory/intermediary only; no stablecoin-issuer licence |
| Nigeria | No distinct stablecoin category; classified by function — asset-backed as securities (ISA 2025), payment-focused under CBN; property under Finance Act 2023 | Securities and Exchange Commission (SEC) | Central Bank of Nigeria (CBN); FIRS; EFCC; NITDA; NFIU | Investments and Securities Act (ISA) 2025; CBN VASP Banking Guidelines (Dec 2023); SEC Rules on Digital Assets | ISA 2025 enacted 31 Mar 2025 | VASP registration; activity categories (DAX, DAOP, DAC, RATOP, DAI/DAPO, Ancillary) |
Table 2: Issuance Licensing Requirements
This table compares who may issue stablecoins, capital thresholds, and governance standards across jurisdictions. See Issuance Licensing Frameworks for the synthesised cross-jurisdictional analysis.
| Country | Who Can Issue | Capital Requirement | Governance Requirements | Processing Time | Key Statute |
|---|---|---|---|---|---|
| United States | Bank/IDI subsidiaries; OCC-supervised nonbanks; state-chartered entities under substantially-similar regimes; non-financial public companies only with unanimous SCRC approval | OCC NPRM: $5M floor for de novo PPSIs (first 3 yrs), Tier 1 only; conditional charters $6.05M–$25M | BSA/AML officer, AML/CFT program, fit-and-proper officers/directors, board oversight, internal audit, ~9-18 FTE compliance team | OCC charter: 30-day completeness + 120-day decision; ~6-12 months realistic | GENIUS Act; OCC NPRM (Feb 25, 2026) |
| Canada | Non-prudentially-regulated issuers (federally-regulated FIs, central banks/CBDCs, algorithmic/commodity-backed, closed-loop excluded) | Not specified in file (deferred to forthcoming regulations); Bank of Canada allocated $10M over two years for supervisory buildout | Application covering corporate/ownership structure, technology, governance, cybersecurity, financial condition; lawyer + certified accountant attestations; national security review | Not specified; framework expected in force 2027 after 12–18 months regulatory development | Stablecoin Act (Division 45, Part 5, Bill C-15); CSA Staff Notice 21-333 |
| Brazil | Authorised SPSAVs (intermediaries, custodians, brokers); eligible authorised FIs by BCB notification | R$10.8M–R$37.2M (~US$2M–$7M) depending on activity type | Local presence; client asset segregation; independent audits; governance; cybersecurity; independent technical certification (Instruction 701/2026) | 270-day grandfathering from 2 Feb 2026 (to ~30 Oct 2026) to notify/apply/migrate | BCB Res. 519/520/521; Instruction 701/2026 |
| Bermuda | Single Currency Pegged Stablecoin Issuers (SCPSIs) holding a DABA licence; banks (e.g., Jewel Bank) | Capital sufficient for wind-down scenarios; prudential/capital adequacy under SCPS Guidance (specifics via supervisory dialogue) | Governance, risk management, operational resilience, recovery/resolution planning, market-maker due diligence | Class T 3–12 months pilot; Class M ~12 months; Class F perpetual (tiered sandbox pathway) | DABA 2018; SCPS Guidance (Nov 2024) |
| EU | EMTs: only credit institutions or e-money institutions (Art 48); ARTs: any EU-established legal person with Art 21 authorisation; credit institutions notify + white paper only | ART own funds highest of EUR 350,000, 2% of average reserve assets, or 25% of preceding year's fixed overheads (up to 3% for significant ARTs); EMT/EMI EUR 350,000 minimum | Registered office in EU; fit-and-proper management body; 1+ EU-resident director; CCO, MLRO, CRO; place of effective management in EU | Statutory ~105 working days (25 completeness + 40-60 decision); actual 6-12 months from substantive engagement | MiCA Articles 16-21 (ARTs), Article 48 (EMTs) |
| United Kingdom | FCA-authorised firms established in the UK (offshore issuers cannot obtain authorisation) | FCA prudential (CP25/15/CP25/42) — capital/liquidity tailored to issuance risk; figures not yet final | UK presence; SM&CR (up to 6 SMFs Core, 17 Enhanced); ~3-4 UK senior individuals; operational resilience | Application window 30 Sep 2026 - 28 Feb 2027; commencement 25 Oct 2027 | FSMA 2000 (as amended); Cryptoassets Regulations 2026; FCA CP25/14 (proposed) |
| Switzerland | Issuers taking public deposits need a banking or FinTech licence, or rely on a Swiss-bank default guarantee exemption; proposed FinIA reserves Regulated Stablecoin issuance to Payment Institutions | Banking-law prudential capital (full licence) or FinTech licence (deposits up to CHF 100m, uninvested, no interest); Payment Institution reserve composition not yet finalised | Non-bank issuers must join a recognised SRO or submit to direct FINMA AML supervision; FINMA Fit & Proper for licensees | Not verified (no statutory processing window stated) | Swiss Banking Act (Art 1a, 1b); Banking Ordinance Art 5(3)(f); FINMA Guidance 06/2024; proposed FinIA amendments |
| Turkey | No domestic stablecoin issuance regime; framework licenses CASPs (trading/custody) only | TRY 100M (platform operators ~USD 2.8m); TRY 50M (custody-only ~USD 1.4m) | Data centres physically in Turkey; ISO/IEC 27001; mgmt 5 yrs experience; suitability testing for >10% owners | Incumbents: apply by 30 Jun 2025; obtain operating licence by 30 Jun 2026 or wind down | Law No. 7518; CMB Communiqués III-35/B.1 (platform), III-35/B.2 (custody) |
| Japan | Only licensed banks, registered fund transfer service providers, and trust companies | Issuers: per-category (banking capital/Basel for banks; fund-transfer Type I/II/III tiers). Intermediaries (EPIESP): minimum capital JPY 10M, positive net assets | Bank: full prudential/Basel; FTSP: registration; trust: bankruptcy-remote structure; EPIESP membership in JVCEA (or equivalent compliance) | Framework in force since 1 Jun 2023; first EPIESP registration (SBI VC Trade) Mar 2025; JPYC FTSP registered Aug 2025 | Payment Services Act (Act No. 59 of 2009, as amended 2022/2025); Banking Act; Trust Business Act |
| Singapore | MPI licensees issuing solely from Singapore; SGD/G10-pegged; banks covered regardless of circulation; non-banks must exceed S$5m SCS in circulation | Minimum base capital higher of S$1m or 50% of annual operating expenses | In-house local compliance officer (no offshore for DPT); 1+ exec director SG citizen/PR or EP-holder; Fit & Proper; permanent SG office with staff | MAS targets ~120 business days; total end-to-end 12-18 months typical; Paxos/StraitsX ~8 months IPA-to-licence | Payment Services Act 2019; SCS framework; legislative codification pending mid-2026 |
| Hong Kong | HKMA-licensed issuers; must be incorporated in HK, or an authorised institution (bank) incorporated outside HK | Minimum paid-up capital HK$25M (~US$3.2M) | CE, directors, stablecoin manager and controller HK-based with fitness/propriety/expertise; viable business plan with concrete use cases | Initial application deadline 30 Sep 2025; PES deadline 31 Oct 2025; first 2 licences granted 10 Apr 2026 (of 36 applications) | Stablecoins Ordinance (Cap. 656) |
| South Korea | Pending — DABA proposes FSC authorisation before issuance; bank-vs-fintech dispute unresolved (BOK favours bank-only, FSC/DPK favour broader eligibility) | Proposed KRW 500M (~USD 360,000) minimum paid-in capital for asset-linked digital asset issuers (pending, not in force) | Not verified — governance/risk-management adequacy expected but no published headcount/substance rule | Not verified — no statutory processing window published | Digital Asset Basic Act — pending bill, not enacted |
| Australia | Entities holding an AFSL (stablecoins classified as financial products); proposed major issuers register with APRA | AFSL adequate-financial-resources requirements; specific stablecoin capital not verified in primary statutory text (to be set in regulations/APRA standards) | AFSL obligations + AFCA membership; APRA prudential standards proposed for major SVFs (not full ADI/bank licensing) | ASIC no-action position until 30 Jun 2026 (must lodge AFSL by then); class exemption Instrument 2025/631 relief until 1 Jun 2028 | Corporations Act 2001; ASIC Instrument 2025/631; proposed Payment Entities (Prudential Regulation) Bill 2026 |
| India | No licensing regime; no entity authorised to issue stablecoins. Proposed (not enacted): limited to regulated entities (banks, NBFCs) | None mandated (proposed future: minimum capital and liquidity stress testing — not enacted) | None for issuance (VDASPs must register with FIU-IND for AML); no governance standards for issuers | No regime; discussion paper shelved again April 2026 (reportedly 5th delay) | No issuance statute (proposed COINS Act 2025 with CARA authority — not enacted) |
| UAE | AED tokens: UAE-incorporated entities (excl. DIFC/ADGM), CBUAE-licensed; non-AED: VARA Cat 1 or ADGM FSRA; banks via wholly-owned subsidiaries | CBUAE DPT: AED 15M (~USD 4.1m) + 0.5% outstanding face value (or 2% bank-subsidiary); VARA FRVA: AED 10M; ADGM FRT: USD 2M | UAE incorporation + physical office; whitepaper approval; UAE-resident key personnel (Responsible Manager, MLRO); FRT issuers cannot carry other regulated activities | CBUAE 4-10 months; VARA 3-6 months; ADGM 3-6 months IPA (12-24 months end-to-end) | CBUAE PTSR (Art. 13/14/15); VARA Issuance Rulebook (Annex 1 FRVA); ADGM FSMR / FRT framework |
| Bahrain | Locally incorporated Bahraini Joint Stock Company (BSC) | Minimum paid-up capital BHD 250,000 (~USD 663,000) | 3-year track record in stablecoin issuance/crypto domain; governance, IT architecture, shareholder disclosures, internal controls | CBB decisions within 60 calendar days | SIO Module (Volume 6 of CBB Rulebook) |
| South Africa | No specific stablecoin-issuer licensing framework; CASP licensing covers advisory/intermediary services only | No issuance-specific capital requirement (FAIS fit-and-proper: operational ability, financial soundness) | CIPC registration; FSP licence; fit-and-proper; key individuals with crypto expertise | Up to six months (potentially longer with backlog) | FAIS Act 2002 (CASP licensing); no enacted stablecoin-issuer statute (IFWG discussion-paper stage) |
| Nigeria | Stablecoin issuers register as VASPs (register both tokens and offerings with SEC); local incorporation, resident CEO | DAX/DAC NGN 2 billion (~USD 1.4m); DAOP/RATOP NGN 1 billion (from 16 Jan 2026, SEC Circular 26-1); stablecoin-issuer-specific figure not verified | Local incorporation, resident CEO; Fidelity Insurance Bond (min 25% paid-up capital); KYC/AML; white papers; SEC-approved custodians | Revised capital compliance deadline 30 Jun 2027 | ISA 2025; SEC Rules on Issuance, Offering Platforms and Custody; SEC Circular No. 26-1 |
Table 3: Reserve Requirements
This table covers reserve backing ratios, eligible assets, segregation, audit standards, and rehypothecation. See Reserve Requirements for the synthesised analysis.
| Country | Reserve Ratio | Qualifying Assets | Segregation | Audit / Attestation | Redemption Backing |
|---|---|---|---|---|---|
| United States | 1:1 minimum | USD, insured deposits, T-bills (≤93 days), repos/reverse repos backed by Treasuries, government MMFs, central bank reserves | Required; reserves segregated from operational funds | Monthly executive-certified reports examined by registered public accounting firm; audited annual financials if >$50B outstanding | No rehypothecation of reserve assets |
| Canada | Full 1:1 — reserves must equal or exceed par value (federal Act); CSA: 1:1 to CAD or USD | Reference fiat plus HQLA (expected: short-term GoC T-bills, insured bank deposits); CSA FBCA: cash and cash equivalents only | Held by qualified custodian (federally regulated trust companies, Schedule I banks with BoC approval); segregated from custodian's and issuer's assets, protected from creditor claims | Monthly certified accountant statements; CSA: monthly assurance reports + audited annual financial statements | Reserve assets may not be pledged, encumbered, or used for anything other than redemptions |
| Brazil | No standalone 1:1 statutory reserve regime; proof-of-reserves via Instruction 701/2026 certification (Art. 65 of Res. 520) | Not verified (permitted reserve assets not prescribed in public BCB materials) | Mandatory client asset segregation from proprietary assets; firms prohibited from using client assets | Independent technical certification covering asset segregation and proof of reserves; daily/attestation cadence not verified | Algorithmic stablecoins banned, so only asset-backed models permitted; FX classification brings FX prudential oversight |
| Bermuda | 100% value parity — backing assets must equal total value of outstanding stablecoins | High-quality liquid assets; specifics determined through supervisory dialogue | Bankruptcy remote from group entities, issuers, managers, or parties involved in token issuance | Independent attestation reports required (expected monthly); mandatory stress testing | Backing assets held in bankruptcy-remote structures; no creditor claims on backing assets |
| EU | Reserve of assets at all times sufficient to meet all token-holder claims; aggregate value must at all times equal/exceed claims (1:1 backing) | Highly liquid financial instruments with minimal market/credit/concentration risk; ART min 30% (60% significant) as deposits in credit institutions; EMT min 30% segregated bank deposits, up to 70% low-risk liquid instruments same currency | Legally and operationally segregated from issuer's estate and from other token reserves (Art 37); custodian separate legal entity; placed within 5 working days | Independent reserve audits at least semiannually; reported to authority within 6 weeks; published within 2 weeks; mark-to-market (amortised cost prohibited) | Reserve maintained solely for token-holders; lending of ART reserves prohibited; recovery and operational redemption plans required |
| United Kingdom | Backing asset pool in statutory trust (all issuers, CP25/14); systemic: BoE 40%/60% (Nov 2025, under revision downward) | On-demand deposits + govt debt ≤1yr (core); expanded: longer public debt, repos, limited MMFs | Backing assets segregated by stablecoin product (not pooled); held in statutory trust; min 5% on-demand deposits | Daily reconciliation; annual independent audit of disclosures; quarterly reserve attestation (systemic, BoE) | Backing must always equal outstanding tokens; excess removed/shortfalls topped up within one business day |
| Switzerland | No dedicated stablecoin ratio; default guarantee must cover at least the total of all stablecoin-holder claims; FinTech licence effectively 100% cash reserve (deposits uninvested) | Banking-licence holders: Basel III prudential standards; FinTech: deposits must remain uninvested (no income instruments); DCHF/tCHF backed by SNB sight deposits | DLT Act provides explicit segregation of custodied crypto-assets (individual attribution, continuous beneficial-owner control); default guarantee gives each customer an individual claim against guaranteeing bank | Not verified (no dedicated stablecoin reserve attestation cadence; banking-law audit applies) | Default guarantee must cover total claims; total deposits must not exceed guaranteed amount; full-banking-licence prudential reserves cover deposit obligations |
| Turkey | No reserve/backing requirements imposed (framework is CASP-focused, not issuance) | N/A (no domestic issuance regime) | Customer crypto assets segregated from CASP operational assets; protected from creditor/bankruptcy claims | N/A (no reserve audit for stablecoins; CASPs subject to annual audits) | N/A — traded stablecoins (USDT/USDC) backed per foreign issuers' home jurisdictions |
| Japan | Banks: standard banking prudential (no separate 1:1 segregation); fund transfer: 100% of issuance value secured; trust: 100% (pre-2025) / min 50% demand deposits (post-2025, effective 1 Jun 2026) | Fund transfer: money deposits with official depositaries, bank guarantees, or entrusted safe assets (bank deposits, JGBs); trust post-2025: up to 50% in ≤3-month JGBs/US Treasuries or early-terminable time deposits | Fund transfer: client funds strictly segregated from provider treasury; trust: trust structure provides asset segregation (bankruptcy-remote) | Regular external audits by certified public accountants required | 100% backing (fund transfer/trust); par-redemption guarantee defines EPI status |
| Singapore | At least 100% of outstanding SCS at all times (continuous) | Cash, cash equivalents, short-dated (≤3-month residual maturity) government/central-bank debt of peg currency; AA- international-org debt ≤3 months; denominated in peg currency | Held in segregated accounts separate from issuer's own assets; approved custodians (SG-licensed or A--rated overseas with MAS-regulated SG branch) | Monthly independent attestation (published + submitted to MAS) plus annual full audit of reserves | Daily mark-to-market valuation ensuring continuous 100% backing |
| Hong Kong | 100% at all times — market value of reserve assets must equal or exceed par value of outstanding FRS | Bank deposits (term ≤3 months); marketable debt securities (residual maturity ≤1 year); certain cash receivables; approved investment funds; high quality/liquidity/minimal risk | Effective trust arrangements required; reserve assets segregated from issuer's proprietary assets; tokenised reserves permitted; partial overseas custody with HKMA approval | Whitepaper disclosure of reserve arrangements required (specific audit cadence not detailed in file) | 100% par-value backing; statutory par redemption right |
| South Korea | Proposed 100%+ reserves against issued tokens with guaranteed redemption (pending, not in force) | Proposed HQLA — bank deposits at licensed institutions and government bonds (per FSC draft commentary) | Proposed — reserve/customer funds separated from issuer's own balance sheet (pending) | Not verified in enacted text — independent reserve audits anticipated but cadence not in enacted law (bill not passed) | Proposed guaranteed redemption at value of linked currency (KRW or foreign currency) (pending) |
| Australia | Current: adequate financial resources under AFSL. Proposed (Tranche 1): 1:1 backing | Proposed: HQLA — cash at an Australian ADI and short-term high-quality government securities | Proposed: segregated trust accounts with Australian ADIs (plus permitted insurance/alternatives per regulations) | Proposed: monthly reserve disclosures; precise audit cadence not verified in primary statutory text | Proposed: enforceable right to redeem at 1:1 par on demand |
| India | No reserve requirements exist (proposed future: 100% backing — not enacted) | None mandated (proposed: liquid reserves or government securities — not enacted) | No mandated segregation requirements | No mandatory audits or disclosures of issuer financial health | No mandated 1:1 reserve backing; redemptions platform-dependent |
| UAE | CBUAE 100% reserve backing; VARA 100% backing at all times; ADGM full 1:1 (no fractional/synthetic) | CBUAE: segregated cash + (bank-subsidiary) ≥50% cash, rest UAE govt bonds/CBUAE Monetary Bills (≤6mo); VARA: cash/cash-equiv/highly liquid low-risk in reference currency; ADGM: cash equivalents, govt debt ≤3mo, overnight reverse repos, public MMFs | Segregated escrow accounts at UAE-licensed banks (CBUAE/VARA); separate reserve pools per FRT type (ADGM); unencumbered/not pledged | CBUAE: daily reconciliation + daily reporting, monthly external-auditor confirmation, bi-annual audit; VARA: daily attestations, monthly third-party assurance, quarterly reviews; ADGM: monthly attestations + annual audit | Circulating supply always matched by reserves; CBUAE legal ring-fencing (customer priority in insolvency); VARA immediate notification if shortfall >1% |
| Bahrain | 1:1 reserve ratio — reserves equal to or exceeding par value of all outstanding stablecoins at all times | High-quality, liquid assets meeting CBB risk criteria | Segregated accounts with authorised third party (bank/investment firm/custodian) under written contract; no commingling with operating funds | Annual external audits of reserve assets | Reserves must at all times equal/exceed par value of outstanding stablecoins |
| South Africa | No stablecoin-specific reserve requirements exist | N/A (six ZAR-pegged stablecoins set own reserve terms) | Not regulated for issuers (gap identified by IFWG Diagnostic) | No independent reserve audit requirements (critical gap per IFWG) | Not regulated; varying redemption terms without standardisation |
| Nigeria | Verifiable reserves backing all issued tokens; cNGN 1:1 peg to Naira | cNGN reserves held in commercial banks under SEC supervision | Assets placed with SEC-approved digital asset custodians | Regular independent audits of reserve holdings; transparent reporting (cNGN flagged for absence of continuous proof-of-reserve) | Reserves must back all issued tokens |
Table 4: Redemption Rights
This table captures redemption rights, timeframes, conditions, and insolvency priority. See Redemption Rights and Holder Protection for the full analysis.
| Country | Redemption Right | Timeframe | Conditions | Priority in Insolvency |
|---|---|---|---|---|
| United States | Public disclosure of redemption procedures required (GENIUS Act); FDIC prudential NPRM proposes redemption mandate | FDIC prudential NPRM (Apr 7, 2026): two-business-day redemption; NYDFS state guidance: T+2 | Per compliant redemption order; redemption procedures publicly disclosed | Not verified |
| Canada | Redeemable at par (face value) for underlying reserve asset in referenced fiat currency (Stablecoin Act, pending in-force) | Not specified — maximum redemption timeframes deferred to forthcoming regulations | Publicly disclosed redemption policies; operational capacity for normal and stressed conditions; recovery/wind-down planning | Reserves protected from creditor claims even in bankruptcy (segregation requirement) |
| Brazil | No explicit statutory redemption right; governed by issuer contractual terms | Not specified (governed by FX regulations and contract) | FX reporting requirements and transaction limits apply to stablecoin-to-fiat conversions | Not verified |
| Bermuda | Right to redeem at par value against referenced fiat currency | Timely redemption; operational resilience to support continuous redemption capacity (no specific T+ stated) | Published redemption policies; recovery/resolution planning for stressed conditions or orderly exit | Bankruptcy-remoteness ensures backing assets remain available for token holders even if issuer/group insolvent |
| EU | EMTs: direct claim at par value at any time, no fees (Art 49); ARTs: right of redemption at all times at market value of referenced assets or delivery (Art 39) | EMTs redeemable at any time; ART white paper specifies conditions/thresholds/procedures | EMT no redemption fees; ART conditions/thresholds/procedures set in white paper; interest/remuneration prohibited (Arts 40 & 50) | Reserve assets used exclusively for benefit of token-holders; legally shielded from issuer's general creditors in insolvency (Art 37) |
| United Kingdom | Direct right to redeem at par value in reference fiat for all holders (retail and non-retail) — proposed CP25/14 | By end of the next business day after valid request | No minimum amounts; no onerous conditions; fair/objective order; suspension only in exceptional circumstances | Robust legal claim to redemption (systemic, BoE); statutory trust over backing assets |
| Switzerland | No stablecoin-specific redemption right; contractual claim against issuer; banking-law depositor protections; FINMA Guidance requires uncomplicated/rapid guarantee enforcement | Not verified (no prescriptive statutory timeline; set by contract, subject to "uncomplicated and fast" guarantee exercise) | Default guarantee: each customer has individual claim against guaranteeing bank; exercisable on issuer insolvency without impediment; claim due at time of insolvency | Banking-law depositor preference in insolvency; DLT Act explicit segregation of custodied crypto-assets; default-guarantee individual claim against bank in issuer bankruptcy |
| Turkey | No stablecoin-specific redemption rights; governed by foreign issuers' terms | N/A | Withdrawal rights subject to MASAK delays (72h new users / 48h subsequent) | Customer assets cannot be seized by CASP creditors or included in bankruptcy estate |
| Japan | All EPI types must be redeemable at face value in the pegged fiat currency; par-redemption is the defining EPI characteristic | Upon request to the issuer (redemption is a fund remittance transaction / kawase-torihiki); specific timeframe not stated | EPISPs must implement transaction revocation rights and loss compensation mechanisms; tokens without par-redemption guarantee fall outside EPI classification | Banks: deposit insurance up to JPY 10M per depositor per bank; trust: bankruptcy-remote segregation; FSA domestic asset holding orders (2025 amendment) strengthen recovery for Japanese users |
| Singapore | Direct legal claim to redeem at par value (holders transacting directly with issuer) | Par value within 5 business days of legitimate redemption request (intermediary transfers within 3 business days) | Any conditions must be reasonable and disclosed upfront before acquisition; MAS may extend liquidation timelines in market stress | Not verified (no specific insolvency-priority provision stated; structural direct legal claim required) |
| Hong Kong | Statutory right to redeem HKMA-licensed FRS at par value in the reference fiat currency | One business day for onboarded customers (direct business relationship) | Redemption conditions must be "reasonable and not unduly burdensome"; customers vs non-customer holders distinction | Not specified in file (statutory managers may be appointed; reserve segregation via trust) |
| South Korea | Proposed guaranteed redemption (pending under DABA; not yet in force) | Not verified (no statutory redemption timeframe; bill not passed) | Proposed — feasible and appropriate redemption method and reserve plan required (pending) | Not verified (no enacted provision) |
| Australia | Proposed (Tranche 1): enforceable right to redeem at 1:1 par on demand; no enacted statutory redemption right yet | On demand (proposed); specific timeframe not verified in primary statutory text | To be set in subordinate regulations/APRA prudential standards — not verified | Not verified (segregated trust structure proposed; detailed insolvency priority not specified in file) |
| India | No formal redemption policies; redemptions remain platform-dependent | N/A — no statutory redemption right | N/A — no licensing regime | N/A (Madras HC Oct 2025 recognised crypto as property capable of being held in trust, but no statutory insolvency priority) |
| UAE | CBUAE: explicit redemption at par; VARA: redemption rights in whitepaper, issuer must guarantee; ADGM: explicit FRT redemption rights | CBUAE: at par without delay, no later than next business day; ADGM: timely and efficient manner | ADGM yield-bearing FRTs permitted if reserves exceed par but no marketing as investment/savings | CBUAE: consumer priority claims on reserves in insolvency (legal ring-fencing) |
| Bahrain | Direct legal right to redeem at par value | Processing within five business days | Mandatory non-technical whitepaper enabling informed decisions | Not explicitly stated (segregated custody with authorised third parties) |
| South Africa | No standardised stablecoin redemption rights (varying terms; gap identified by IFWG) | Not specified | Set by individual issuers without regulatory oversight | Not specified |
| Nigeria | Not explicitly established as a stablecoin-specific statutory right in the file | Not specified | Governed by issuer terms; cNGN purchased/sold via licensed exchanges | Not specified |
Table 5: Systemic Risk Designation
This table compares threshold-based oversight for systemically important stablecoin arrangements. See Systemic Risk Designation for the full analysis.
| Country | Designation Regime | Threshold | Enhanced Requirements |
|---|---|---|---|
| United States | State $10B threshold for state-vs-federal regulation; SCRC certification of state regimes | $10B consolidated outstanding (state option ceiling); $25B (large issuer reserve rules); $50B (audited annual financials) | State-qualified issuers exceeding $10B must notify OCC within 5 days and transition to federal framework within 360 days or cease net new issuance |
| Canada | No explicit systemic-risk designation tier; federal Act applies to interprovincial/international issuers; provincial securities overlay | N/A | National Security Review — Minister of Finance may prohibit/restrict issuance by entities controlled from high-risk jurisdictions |
| Brazil | FX integration mechanism rather than a dedicated systemic-risk designation | Per-transaction caps: USD 500,000 (banks/authorised FIs); USD 100,000 (non-bank SPSAVs); eFX investments abroad ~USD 10,000/transaction (Res. 561) | Resolution 561/2026 bans virtual-asset settlement of the offshore leg of regulated eFX cross-border payments (effective 1 Oct 2026) |
| Bermuda | No specific systemic-risk designation regime; tiered DABA licensing (T/M/F) plus SCPS prudential standards | N/A | Capital adequacy, wind-down planning, stress testing under SCPS Guidance; proposed DABA amendments to grant BMA rulemaking on capital/solvency/liquidity |
| EU | Significant ART/EMT designation by EBA (Arts 43-44 ARTs; 56-57 EMTs); EBA direct/joint supervision | Meet at least 3 of: >10m holders; >EUR 5bn issued/market cap/reserve; >2.5m daily transactions; >EUR 500m daily transaction value; plus qualitative international scale / interconnectedness | Min 60% reserves in bank deposits; 40%/60% 1-day/5-day liquidity; up to 3% own funds; enhanced reporting/governance; recovery/redemption plans; non-euro EMT caps (Art 58): cease issuing if >EUR 200m daily value or >1m daily transactions |
| United Kingdom | BoE regulates systemic stablecoins once recognised by HMT as systemically important | Used widely in payments / failure could threaten UK financial stability | BoE reserve allocation (40% at BoE proposed, being lowered); capital = higher of 6mo opex or recovery cost; holding limits (individual limits being abandoned for aggregate issuance caps, May 2026) |
| Switzerland | Not verified (no dedicated stablecoin systemic-risk designation regime; full banking licensees subject to standard prudential supervision) | Not verified | Not verified |
| Turkey | No systemic stablecoin designation regime | N/A | N/A |
| Japan | No separate systemic-risk designation tier; tiered by issuer type (bank/FTSP/trust) and fund-transfer Type I/II/III transaction sizes | Fund transfer categories: Type I (>JPY 1M/transaction), Type II (≤JPY 1M), Type III (≤JPY 50,000) | Different capital and compliance requirements per fund-transfer category; FSA domestic asset holding orders during insolvency |
| Singapore | Systemically important stablecoin arrangements may be designated as Designated Payment Systems under the PSA | Not verified (no quantitative threshold stated) | Enhanced MAS supervision and transaction finality protections |
| Hong Kong | No separate systemic-risk designation tier described; uniform licensing regime under the Ordinance | N/A (high uniform bar; HKMA states overall licence numbers will remain very limited) | N/A — single licensing standard applies |
| South Korea | Not verified (no systemic-risk designation regime; no stablecoin statute enacted) | Not verified | Not verified |
| Australia | Proposed graduated APRA prudential regime for major SVF/currency stablecoin issuers (Tranche 1, exposure draft) | Aggregate credit of facilities exceeding "currently proposed to be A$200 million" (subject to regulations) | Register with APRA and comply with APRA prudential standards (registration, not licensing; not treated as ADI/bank) |
| India | N/A — no stablecoin framework or systemic designation regime | N/A | N/A |
| UAE | No single systemic-designation regime; CBUAE may impose higher aggregate capital based on scale/complexity | Scale and complexity (CBUAE discretion) | CBUAE higher aggregate capital; small issuer exemption (reserves ≤AED 500,000 and <100 holders) |
| Bahrain | No systemic designation regime | N/A | N/A |
| South Africa | No systemic stablecoin designation regime (SARB classified crypto/stablecoins as material financial stability risk, Nov 2025) | N/A | PA drafting BCBS-aligned prudential standard for bank crypto-asset exposures (banks, not issuers) |
| Nigeria | No systemic stablecoin designation regime | N/A | N/A |
Table 6: AML/KYC Requirements
This table compares AML regimes, Travel Rule thresholds, and reporting obligations. See AML/KYC Compliance for the synthesised analysis.
| Country | AML Regime | Threshold | Reporting | Travel Rule |
|---|---|---|---|---|
| United States | Bank Secrecy Act; PPSIs/issuers treated as financial institutions/MSBs; FinCEN tailored AML rules | CTRs for transactions >$10,000; FinCEN registration within 180 days | SARs, CTRs, CIP/KYC; FinCEN/OFAC joint NPRM (Apr 8, 2026) mandates AML/CFT + sanctions compliance program | Yes — originator/beneficiary info for transfers >$3,000 (FATF Rec 16) |
| Canada | PCMLTFA — stablecoin issuance is "dealing in virtual currency"; MSB registration with FINTRAC | Large Transaction Reports for virtual currency transactions ≥C$10,000 (within 5 business days) | STRs, KYC, compliance programme, 5-year record-keeping; CARF reporting from 1 Jan 2026 | Yes — identifying info must accompany virtual asset transfers above prescribed thresholds |
| Brazil | BCB resolutions plus existing financial-sector AML law; aligned with FATF; UN sanctions (Law 13,810/2019) | Residents/entities via foreign/DeFi/P2P must report transactions exceeding R$30,000 monthly | KYC, risk assessments, fraud controls; mandatory cross-border reporting begins 4 May 2026 | Phased: Phase 1 (self-declarations) 2 Feb 2026–1 Feb 2027; Phase 2 enhanced 2 Feb 2027–1 Feb 2028; full compliance from 2 Feb 2028 |
| Bermuda | Proceeds of Crime Act 1997 and AML/ATF Regulations 2008; member of Caribbean FATF | N/A (full KYC/CDD for all clients) | SARs to Financial Intelligence Agency (FIA); transaction monitoring; sanctions screening; designated compliance officer | Not verified (file describes sanctions screening and transaction monitoring but no explicit travel-rule threshold) |
| EU | EMT/ART issuers are obliged entities under EU AML framework (AMLD5; AMLR (EU) 2024/1624 applicable 1 Jul 2027; AMLA supervises riskiest CASPs) | TFR (Travel Rule) no de minimis threshold; verify originator identity for transfers >EUR 1,000 from self-hosted wallets; AMLR identify/verify especially >EUR 1,000 | Ongoing transaction monitoring; sanctions screening; suspicious activity reports to national FIUs | Transfer of Funds Regulation (EU) 2023/1113 — originator/beneficiary info for all crypto transfers regardless of amount; enforceable 30 Dec 2024, no grace period |
| United Kingdom | Money Laundering Regulations 2017 (since Jan 2020); future: full FCA authorisation with FSMA-level AML | FATF Travel Rule applies to crypto wire transfers | SARs to National Crime Agency (NCA); financial promotions regime since Oct 2023 | FATF Travel Rule applied for cryptoasset wire transfers |
| Switzerland | Anti-Money Laundering Act (AMLA) — FINMA holds AMLA "almost always" applicable; issuers are financial intermediaries; non-banks must join an SRO or be under direct FINMA supervision | CHF 1,000 Travel Rule threshold (stricter than FATF); linked-transactions within 30 days must prevent circumvention | Identify/verify all holders incl. secondary-market holders; beneficial ownership; ongoing monitoring; report suspicious transactions to MROS | CHF 1,000 threshold for transmission of sender/recipient data; technical measures against threshold circumvention |
| Turkey | MASAK under Law No. 5549; CASPs are obligated entities | Stablecoin transfer limits: USD 3,000 daily / USD 50,000 monthly (MASAK Circular No. 29) | Suspicious transaction reports within 72 hours; 20-char min transaction descriptions | Fully implemented as of 25 February 2025 (enforced by MASAK) |
| Japan | Act on Prevention of Transfer of Criminal Proceeds (APTCP, Act No. 22 of 2007, amended 2022); first major developed country to implement FATF travel rule | No de minimis threshold — travel rule applies to all transactions regardless of amount | Suspicious transaction reporting to JAFIC; identity verification (KYC); records retained for statutory period | Effective 1 June 2023; covers crypto-asset and EPI transfers; 5 jurisdictions added 1 May 2026 (specific names not verified) |
| Singapore | MAS Notice PSN02 (AML/CFT for DPT Service); applies to all DPT issuers/intermediaries; revised 30 Jun 2025 | CDD required from the first dollar of DPT transactions, no de minimis threshold | Suspicious Transaction Reports (STR) to STRO; enterprise-wide risk assessment; ongoing monitoring; external AML/CFT audit before licence | FATF Travel Rule implemented via PSN02 (DPT transfers treated as value transfers; originator/beneficiary info required) |
| Hong Kong | HKMA AML/CFT requirements for issuers (CDD on customers, not non-customer holders); SFC VATPs under AMLO full AML/CFT | Not specified in file | Suspicious transaction reporting to Joint Financial Intelligence Unit (JFIU) for VATPs | Travel rule compliance for virtual asset transfers (VATPs); aligns with FATF standards |
| South Korea | VASPs register with KoFIU under Act on Reporting and Using Specified Financial Transaction Information; ISMS certification; real-name bank accounts; FATF-aligned | Zero-threshold travel rule (early 2026) — previous 1 million KRW (~$700) minimum eliminated | Mandatory suspicious transaction reporting to KoFIU; risk-based CDD | Zero-threshold travel rule covering all transfers including stablecoins and unhosted wallets — one of the most aggressive globally |
| Australia | Anti-Money Laundering and Counter-Terrorism Financing Act 2006; digital currency exchanges register with AUSTRAC | Not specified in file (general DCE registration + KYC mandatory) | Mandatory suspicious matter reporting to AUSTRAC; 7-year record keeping | AUSTRAC implementing FATF travel rule for virtual asset transfers |
| India | PMLA 2002 (VDA activities brought under PMLA March 2023); FIU-IND oversight; all VDASPs must register | 1% TDS applies to transfers exceeding ₹50,000 (specified persons) or ₹10,000 (others) under Sec 194S | Mandatory suspicious transaction reporting to FIU-IND; KYC verification; record keeping; CERT-In audit + PACT certificate (Sept 2025) | Compliance required for cross-border transfers per FATF standards |
| UAE | Federal Decree-Law No. 20 of 2018 + Cabinet Decision No. 10 of 2019; FATF-aligned | FATF Travel Rule for transactions above USD 1,000 (or local equivalent) | KYC, suspicious transaction monitoring/reporting; VARA quarterly client risk assessments; enhanced due diligence | FATF Travel Rule adopted — ADGM (2023, guidance June 2025); VARA (Rulebook v2.0, May 2025); CBUAE (May 2023 guidance, effective 1 July 2023) |
| Bahrain | AML Module in CBB Rulebook Volume 6; FATF-aligned | Not specified (CDD, EDD for high-risk customers) | Suspicious transaction reporting; record-keeping; compliance officer; employee training; IFRS and AAOIFI standards | FATF-aligned (not separately detailed) |
| South Africa | FICA — CASPs are accountable institutions (since 19 Dec 2022); FATF-aligned | Travel rule R5,000 (full data/verification at/above; basic info under R5,000, no de minimis threshold) | Suspicious transaction reporting; sanctions screening; FIC registration; CDD | FIC Directive 9 — issued 13 Dec 2024, effective 30 April 2025 (FATF Rec. 16) |
| Nigeria | Money Laundering (Prevention and Prohibition) Act 2022; VASPs are financial institutions; FATF Rec. 15-aligned | Large payment reporting thresholds (not specified numerically) | CDD with biometric onboarding; suspicious transaction reporting to NFIU; sanctions screening; SCUML/EFCC enforcement | Not separately detailed (FATF-aligned) |
Table 7: Taxation
This table compares tax classification, capital gains treatment, VAT/GST, and reporting frameworks for stablecoin transactions. See Taxation Frameworks for the synthesised analysis.
| Country | Tax Classification | CGT Rate | VAT/GST Treatment | Reporting Framework |
|---|---|---|---|---|
| United States | Property (IRS Notice 2014-21); unchanged by GENIUS Act | Capital gain/loss on dispositions (stablecoin sales/swaps are taxable events) | N/A | Form 1099-DA: gross proceeds from Jan 1, 2025; cost basis from Jan 1, 2026; de minimis non-reporting for qualified stablecoin sales <$10,000/yr; proposed <$200 CGT exemption not enacted |
| Canada | Commodity under Income Tax Act (CRA) | 50% inclusion rate; raised to 66.7% for corporations/trusts and individuals on gains >$250,000 (Budget 2024) | N/A (file addresses income/capital gains; business income makes 100% taxable) | OECD CARF automatic reporting from 1 January 2026; CASPs report transactions and customer identities to CRA |
| Brazil | Crypto assets (incl. stablecoins) taxed; FX-classified stablecoin transactions subject to FX tax rules incl. IOF | Capital Gains Tax only if monthly profits exceed R$35,000 (~US$6,500); progressive rates above threshold | IOF (Financial Operations Tax) applies to FX transactions | Declare holdings ≥R$5,000 in IRPF; monthly reporting of foreign/DeFi transactions >R$30,000; DeCripto system (OECD CARF-based) launched July 2025 |
| Bermuda | No tax-specific regime for stablecoins | No capital gains tax | No value-added tax | Standard Bermuda government fees and annual licence fees; no corporate income tax, no withholding tax |
| EU | MiCA contains no tax provisions; income tax not harmonised (varies by Member State) | Capital gains generally subject to income tax in most Member States (not harmonised); MiCA does not address direct taxation | Crypto-asset exchange exempt from VAT per CJEU Hedqvist (C-264/14); EMTs as e-money likely benefit from financial-services VAT exemptions (Member State interpretation varies) | DAC8 (Directive (EU) 2023/2226) — mandatory crypto-asset tax reporting; transpose by 31 Dec 2025, apply from 1 Jan 2026, first reports by 30 Sep 2027 |
| United Kingdom | Property (not currency); same as other cryptoassets (HMRC) | CGT 18% or 24% by income band; annual allowance GBP 3,000 (2025/26) | Not specified as stablecoin-specific; income tax 20%/40%/45% on income events | Crypto platforms must report to HMRC from 1 Jan 2026 (CARF); first reports due by May 2027 |
| Switzerland | Technology-neutral; treated as private assets (like bonds/stocks/property), not legal tender; FTA publishes annual rate list (31 Dec valuation) | No capital gains tax on private investment gains (movable private assets tax-free); professional traders taxed as income; corporate income tax (federal 8.5% + cantonal) | Not verified (VAT treatment of stablecoins not detailed); wealth tax applies (progressive ~0.05%-1%, canton-dependent) | CARF reporting from 1 Jan 2027 (crypto platforms report Swiss users to SFTA); authorities expected to receive info from ~2028 |
| Turkey | No dedicated crypto tax; taxed under general income tax | Progressive income tax 15%-40% on trading profits; proposed 10% withholding tax WITHDRAWN from omnibus bill 28 March 2026 | VAT on crypto not yet clarified | OECD CARF alignment expected 2025-2026 |
| Japan | Crypto-assets (incl. stablecoins used in trading) as miscellaneous income currently; EPI-specific tax treatment lacks specific FSA guidance | Current: 15-55% progressive (miscellaneous income); 2025 reform: 20.315% separate taxation for specified crypto assets (15% national + 2.1% surtax + 5% local), upon FIEA reclassification; 3-year loss carry-forward | Consumption tax: crypto-asset transfers currently non-taxable; proposed FIEA reclassification treats as securities-like with 5% in taxable sales ratio | General crypto-asset tax framework applies; EPI-specific guidance not yet issued as of June 2026 |
| Singapore | DPTs treated as intangible property (not currency/legal tender) | No capital gains tax in Singapore; long-term capital-nature gains not taxed; trading gains taxed as income | Supplies of DPTs exempt from GST (since 1 Jan 2020); use as payment disregarded as a supply; stablecoins may fall outside DPT definition for GST due to peg | Not verified (no specific stablecoin tax-reporting regime detailed) |
| Hong Kong | Territorial-source principle applied to crypto/stablecoins; "badges of trade" distinguish trading vs capital | No capital gains tax in Hong Kong; capital gains from long-term holding not taxed | No VAT/GST in Hong Kong; business trading profits subject to profits tax 8.25% (first HK$2M) / 16.5% thereafter | IRD applies badges-of-trade; 2026-27 Budget tax concessions for institutional investors/single-family offices |
| South Korea | Not verified (crypto tax classification for stablecoins not specifically detailed) | 20% on crypto profits exceeding 50 million KRW (~$35,900) annually; NOT in effect — scheduled for 2027 (thrice delayed) | Not verified (VAT/GST treatment not addressed in file) | AI-powered crypto tax system being built ahead of 2027 launch |
| Australia | ATO treats all crypto assets including stablecoins as property subject to Capital Gains Tax (CGT) | CGT on disposal; 50% CGT discount if held >12 months; business income assessable as ordinary income | Crypto transactions GST-free since 2017 (GST may apply to service fees) | Declaration of all crypto holdings/disposals in annual returns; ATO data-matching with exchanges |
| India | Stablecoins taxed as Virtual Digital Assets (VDAs); among world's heaviest crypto tax burdens | 30% flat tax on VDA gains (Sec 115BBH); 1% TDS (Sec 194S); no loss offset/carry-forward; unchanged in Union Budget 2026 | 18% GST on exchange trading fees and related services | TDS at source; no distinction between volatile crypto and stablecoins |
| UAE | Crypto transactions VAT-exempt; virtual assets not subject to personal income/capital gains tax | No personal income tax; no capital gains tax on individuals; 9% corporate tax above AED 375,000 | VAT (5%) exemption effective 15 Nov 2024 retroactive to 1 Jan 2018 (Cabinet Decision 100/2024); fees/commissions and mining still subject to VAT | Not specified |
| Bahrain | No tax on crypto-asset gains | No personal income tax, no corporate income tax, no capital gains tax | 10% VAT generally but payment tokens exempt; most cross-border crypto services not subject | Not specified |
| South Africa | Financial assets under Income Tax Act (not currency); SARS | CGT up to 18% effective (individuals); trading profits income tax 18%-45%; R40,000 annual capital gains exclusion | Not specified as stablecoin-specific | FIFO disposal method; crypto-to-crypto/stablecoin swaps are taxable disposals |
| Nigeria | Digital assets — chargeable gains (NTA 2025, effective 1 Jan 2026), superseding prior flat 10% CGT | Individuals: PIT bands 0%-25% (first NGN 800,000 exempt; top 25% above NGN 50m); companies/VASPs up to 30% | 7.5% VAT on VASP service fees (not on crypto-assets themselves) | Section 25 NTAA monthly VASP returns; NIN/CAC tax-ID harmonisation; OECD CARF adoption effective 1 Jan 2026 |
Table 8: Algorithmic Stablecoin Treatment
This table summarises how each jurisdiction treats algorithmic, crypto-collateralised, and hybrid stablecoins. See Algorithmic Stablecoin Regulation for the full analysis.
| Country | Banned? | Excluded from Framework? | Notes / Post-Terra Response |
|---|---|---|---|
| United States | Not banned, but not eligible for PPSI status | Yes — GENIUS Act governs fiat-backed payment stablecoins; algorithmic/endogenously-collateralised excluded | Remain in regulatory gray area (potential SEC/CFTC jurisdiction); SEC Apr 2025 Covered Stablecoin statement and SEC non-securities exclusion do not apply to algorithmic; Terraform/UST collapse drove $4.47B SEC settlement |
| Canada | Excluded from Stablecoin Act (not eligible), not described as outright banned | Yes — algorithmic or commodity-backed stablecoins excluded from the Stablecoin Act | Also excluded: federally-regulated FIs, central banks/CBDCs, closed-loop stablecoins not marketed for broader payments |
| Brazil | Yes — algorithmic stablecoins banned; Brazilian VASPs may not offer or intermediate purely algorithmic pegs | Purely algorithmic pegs prohibited (not merely excluded) | Ban ensures only asset-backed models permitted (Resolution 521/520 framework) |
| Bermuda | Not verified (file does not state an algorithmic ban) | SCPS Guidance scoped to Single Currency Pegged Stablecoins; algorithmic treatment not addressed | Framework focuses on fiat-pegged stablecoins backed 1:1; no explicit algorithmic-stablecoin provisions in file |
| EU | Not banned by name but effectively inoperable — cannot comply with ART/EMT reserve requirements | Yes — Recital 41 excludes pure supply-adjusting algorithmic tokens from ART category; cannot obtain authorisation under either ART or EMT regime | Effectively excluded because both categories require tangible asset reserves; reinforced post-Terra/LUNA (May 2022, >USD 40bn losses) |
| United Kingdom | Algorithmic stablecoins excluded from "qualifying stablecoin" definition | Yes — only fiat-backed tokens holding fiat (or fiat + other assets) qualify | Algorithmic stablecoins do not qualify for stablecoin authorisation regime |
| Switzerland | Not verified (no specific algorithmic-stablecoin ban stated) | Not specifically addressed; regulated by economic substance under existing financial market law | FINMA applies substance-over-form; deposit-like fiat-backed stablecoins trigger banking regulation; no dedicated algorithmic-stablecoin provision in file |
| Turkey | Not specifically addressed | No dedicated algorithmic stablecoin provisions; all crypto treated under general framework | Law No. 7518 does not create a separate stablecoin/algorithmic category |
| Japan | Not banned, but excluded from EPI/stablecoin framework | Yes — algorithmic stablecoins (not fiat-collateralised) do NOT constitute EPIs; regulated as crypto-assets under PSA crypto-asset provisions (require CAESP registration) | Tripartite split: EPIs (fiat-backed), crypto-assets (algorithmic), security tokens (FIEA) |
| Singapore | Not banned; remain regulated as DPTs under the PSA | Yes — algorithmic stablecoins excluded from the "MAS-regulated stablecoin" SCS designation | Reflects conservative post-TerraUSD/LUNA (May 2022) approach; cannot carry MAS-regulated label; full reserve backing required for SCS |
| Hong Kong | Not banned, but outside scope | Yes — Ordinance applies exclusively to fiat-referenced stablecoins; algorithmic and commodity-backed tokens fall outside the regime | Algorithmic and commodity-backed stablecoins are not covered by the Stablecoins Ordinance |
| South Korea | Not banned, but proposed framework effectively excludes algorithmic-only models (full backing required) | Yes — proposed DABA requires 100%+ reserves and guaranteed redemption, effectively excluding algorithmic stabilisation for licensed stablecoins | Driven by Terra/LUNA collapse (May 2022, ~$40bn losses; Do Kwon sentenced 15 years 11 Dec 2025); proposed framework requires full asset backing |
| Australia | Not stated as banned | Tranche 1 "currency stablecoin"/tokenised SVF framework targets single-currency fiat-backed; algorithmic treatment not specifically addressed in file | File does not specify algorithmic stablecoin treatment; tokenised SVF defined as fixed redemption amounts in single currencies |
| India | Not formally banned, but de facto discouraged; RBI opposes private stablecoins | No framework exists — all stablecoins treated uniformly as VDAs regardless of peg | No specific algorithmic stablecoin treatment; tax framework makes no distinction by asset type |
| UAE | Algorithmic stablecoins (and privacy tokens) strictly prohibited from issuance, service, or promotion (CBUAE); explicitly excluded (ADGM, DFSA) | Yes — algorithmic stablecoins excluded from FRT/payment token definitions across CBUAE, ADGM, DFSA | Algorithmic stablecoins strictly prohibited UAE-wide |
| Bahrain | Only single-currency fiat-backed stablecoins permitted (algorithmic effectively excluded) | Yes — SIO Module scope limited to single-currency fiat-backed stablecoins | Yield-bearing stablecoins permitted, including Sharia-compliant reward-bearing instruments |
| South Africa | Not specifically addressed | No algorithmic-specific provisions (stablecoin issuance broadly unregulated) | Stablecoin stability mechanisms not overseen (gap per IFWG Diagnostic) |
| Nigeria | Not specifically addressed | No specific algorithmic stablecoin provisions; substance-over-form classification | Classification depends on economic function (securities vs payment instrument) |
Table 9: Payment System Integration
This table captures whether stablecoins can be used for payments, their collateral use, and CBDC interaction. See Payment System Integration for the full analysis.
| Country | Payment Use Permitted? | Collateral Use | CBDC Stance |
|---|---|---|---|
| United States | Yes — payment stablecoins are core use case; issuers prohibited from paying interest to holders | Yes — CFTC no-action permits FCMs to accept payment stablecoins as customer margin collateral | CBDCs explicitly excluded from GENIUS Act scope; Fed considering limited payment-rail access for chartered PPSIs |
| Canada | Yes — positioned as payment instruments; yield prohibition (no interest/yield/rewards to holders) | Not verified | Central banks and CBDCs excluded from Stablecoin Act; Bank of Canada research on digital money (stablecoins, tokenised deposits, CBDCs) |
| Brazil | Permitted as FX operations, but Resolution 561/2026 bans stablecoin/crypto settlement of the offshore leg of regulated eFX cross-border payments (effective 1 Oct 2026) | Not verified | Drex (digital real) pivoted away from blockchain (deemed not viable); positioned as institutional settlement infrastructure complementary to private stablecoins, not a retail CBDC |
| Bermuda | Yes — DABA covers payment service provider business using digital assets; government piloting USDC payments | Not verified | Pursuing sovereign-grade "Bermuda Digital Dollar" (fiat-backed stablecoin) via Stellar partnership; framed as government stablecoin rather than a classic CBDC |
| EU | Yes — EMT transfers qualify as payment service under PSD2 (EBA Opinion 10 Jun 2025); full PSD2 compliance required from 2 Mar 2026; PSD3/PSR provisional agreement Nov 2025 | Not verified (collateral use not specifically addressed) | CBDCs and certain e-money tokens excluded from DAC8 reporting; digital euro work proceeds separately (not detailed in file) |
| United Kingdom | Yes — HMT (21 Apr 2026) reversed position to bring UK-issued qualifying stablecoins used for payments into regulated payments perimeter; FCA stablecoin payments a 2026 priority | Not specified | Distinct from CBDC work; BoE systemic regime; digital pound separate |
| Switzerland | Yes — fiat-backed stablecoins function as payment tokens; payment feature "almost always" triggers AMLA; multiple CHF stablecoin projects operational (DCHF, tCHF, ZCHF) | Not verified | SNB wholesale-CBDC work (Project Helvetia); CHFD bank-consortium sandbox pilot explores middle ground between SNB centralisation and decentralised stablecoins |
| Turkey | No — crypto/stablecoin payments prohibited (CBRT April 2021 Regulation on Disuse of Crypto-Assets in Payments) | Not addressed | CBRT conducting digital lira (CBDC) research; not launched |
| Japan | Yes — EPIs are purpose-built payment instruments; redemption is a fund remittance transaction (kawase-torihiki) | Not specified in file | BOJ conducting digital yen pilots since April 2023; no current plans to issue CBDC (June 2025); private stablecoins and digital yen expected to coexist |
| Singapore | Yes — stablecoins regulated as payment instruments under the PSA; positioned for retail payments and cross-border settlement | Not verified (SCS issuers prohibited from lending/staking; broader market collateral use not specified) | Wholesale CBDC pilot (tokenised MAS Bills) ongoing; Project Orchid builds retail CBDC capability "should the need arise", not a commitment; stablecoins/tokenised deposits/CBDC to coexist |
| Hong Kong | Yes — FRS payment use within licensed regime; only HKMA-licensed FRS may be offered to retail | Not specified in file | Not addressed in this file |
| South Korea | Indicative — won-pegged stablecoin a stated national priority (President Lee Jae-myung); bank consortia targeting won-stablecoin launches late 2026, contingent on legislation | Not verified | BOK paused retail Project Hangang (2025) then launched Phase 2 (Mar 2026, 7→9 banks, wholesale CBDC + deposit tokens); Governor Shin Hyun-song prioritises bank-led CBDC + deposit tokens, omits stablecoins |
| Australia | Yes — reform aims to capture stablecoins within modernised payments framework (SVF, payment instruments, payment services categories) | Not specified in file | Not specified in this file (Treasury payments modernisation focus, not CBDC) |
| India | No authorised payment-instrument status; stablecoins not legal tender/authorised payment instruments; used informally for remittances (USDT 4-5% premium) | Not specified in file | RBI prioritises e-rupee CBDC as strategic alternative to private stablecoins; e-rupee circulation fell ~24% to Rs 771.7 crore (31 Mar 2026), ~10 million users |
| UAE | Yes — merchants may accept licensed Dirham Payment Tokens or CBUAE-licensed foreign payment tokens; AE Coin live at point-of-sale (Jan 2026); foreign payment tokens restricted to VA purchases/derivatives | Not specified | Digital Dirham CBDC — retail phase launched December 2025; positioned as complementary to private payment tokens with anticipated interoperability |
| Bahrain | Permitted within licensed framework (issuance, trading, use) | Not specified | Not specified in file |
| South Africa | Crypto/stablecoins for domestic payments are not "money"/"funds"/"payments" under NPSA 1998 and not legal tender (SARB/FSCA Joint Communication, 28 May 2026); fall outside NPSA | Not specified | Not detailed in file |
| Nigeria | Yes — cNGN used for instant payments, cross-border remittances, naira-denominated commerce | Not specified | eNaira (CBN CBDC, Oct 2021); cNGN designed to complement, not substitute, eNaira |
Table 10: International Standards Compliance
This table evaluates alignment with key international regulatory frameworks. See International Standards Synthesis for the detailed analysis.
| Country | FATF Alignment | Travel Rule | CARF Status |
|---|---|---|---|
| United States | Aligned — BSA is FATF-aligned; PPSIs subject to FATF-aligned BSA | Yes — >$3,000 threshold, aligns with FATF Recommendation 16 | Not adopted; uses domestic Form 1099-DA broker reporting regime (Infrastructure Investment and Jobs Act 2021) |
| Canada | Aligned — reserve requirements align with FATF and FSB; framework pursues FSB recommendation alignment | Yes — info accompanies virtual asset transfers above prescribed thresholds (FINTRAC) | Adopted — OECD CARF from 1 January 2026 |
| Brazil | Aligned — AML framework aligned with FATF recommendations; Resolution 561 rationale cites FATF traceability | Phased implementation reaching full compliance from 2 February 2028 | Adopted via DeCripto reporting system (OECD CARF-based), launched July 2025 |
| Bermuda | Aligned — reserve requirements aligned with FATF standards; Caribbean FATF member | Not verified | Not verified |
| EU | Aligned — TFR extends FATF Travel Rule to all crypto-asset transfers | Implemented via Transfer of Funds Regulation (EU) 2023/1113, no de minimis threshold, enforceable 30 Dec 2024 | DAC8 (EU implementation of OECD CARF) applicable from 1 Jan 2026; first reporting year 2026, reports by 30 Sep 2027 |
| United Kingdom | FATF-aligned; MLRs and SM&CR-level AML | FATF Travel Rule applied to cryptoasset transfers | CARF reporting from 1 January 2026; first reports by May 2027 |
| Switzerland | Exceeds FATF — CHF 1,000 Travel Rule threshold stricter than FATF standard; prohibition on anonymous stablecoins | CHF 1,000 threshold (stricter than FATF), with anti-circumvention measures for linked transactions | OECD CARF reporting from 1 Jan 2027; first information exchange expected ~2028 |
| Turkey | FATF-aligned; MASAK AML/CFT framework | Fully implemented 25 February 2025 | Aligning with OECD CARF; implementation expected 2025-2026 |
| Japan | First major developed country to implement FATF travel rule; aligns with FATF standards via APTCP | Effective 1 June 2023; no de minimis threshold; covers crypto-asset and EPI transfers; 5 jurisdictions added 1 May 2026 | Not verified (not mentioned in file) |
| Singapore | Aligned — framework broadly aligns with FATF standards; DTSP regime aligns with FATF VASP enhanced standards | Implemented via PSN02 (no de minimis threshold for DPT value transfers) | Not verified (CARF status not addressed in file) |
| Hong Kong | AML/CFT consultation aligns with FATF standards; SFC VASP regime under AMLO | Travel rule compliance required for virtual asset transfers (VATPs) | Not verified (not mentioned in file) |
| South Korea | Aligned — one of Asia-Pacific's most stringent FATF-aligned AML frameworks | Zero-threshold implementation (early 2026), among world's strictest | Not verified (CARF status not addressed in file) |
| Australia | Aligning with international standards (EU/MiCA, Singapore PSA); AML/CTF Act reform to align with FATF recommendations | AUSTRAC implementing FATF travel rule for virtual asset transfers | Not verified (not mentioned in file) |
| India | PMLA/FIU-IND framework aligns with FATF recommendations; RBI's FSR (Dec 2025) urges global priority on CBDCs over stablecoins | Travel rule compliance required for cross-border transfers per FATF standards | Not verified (not mentioned in file) |
| UAE | Removed from FATF grey list 23 February 2024; next mutual evaluation expected 2026 | FATF Travel Rule adopted across ADGM, VARA, CBUAE (transactions above USD 1,000) | Not specified |
| Bahrain | FATF-aligned (AML Module); IFRS and AAOIFI standards | FATF-aligned | Not specified |
| South Africa | FATF-aligned AML/CFT regime | FIC Directive 9 in force 30 April 2025 (FATF Rec. 16) | Not specified |
| Nigeria | FATF-aligned (ML Act 2022; FATF Rec. 15) | Not separately detailed | OECD CARF adoption effective 1 January 2026 |
Cross-Cutting Key Takeaways
The matrix above resolves into a five-band regulatory spectrum (per the spectrum_position field in each jurisdiction's file), running from comprehensive dedicated regimes through to restrictive postures:
- Band 1 — Comprehensive Dedicated (6 jurisdictions): EU (MiCA, applicable since 30 Jun 2024 — the world's most comprehensive enacted standalone framework), Hong Kong (Stablecoins Ordinance, Cap. 656, in force 1 Aug 2025, first two FRS licences granted 10 Apr 2026), Japan (EPI framework under the Payment Services Act, in force since 1 Jun 2023, with the 2025 Amendment taking effect 1 Jun 2026), Singapore (SCS framework layered on the PSA, legislative codification pending mid-2026), Bahrain (SIO Module, effective Jul 2025, first full issuer licence to AX Coin Bahrain 3 Jun 2026), and the UAE (multi-layered CBUAE PTSR / VARA FRVA / ADGM FRT regimes with live AED stablecoins).
- Band 2 — Integrated (3 jurisdictions): United States (GENIUS Act enacted 18 Jul 2025 but not yet effective; implementing NPRMs from OCC, FDIC, NCUA, and FinCEN/OFAC advanced Feb–May 2026; Tether launched GENIUS-track USAT via Anchorage on 27 Jan 2026), Canada (provincial CSA regime plus the federal Stablecoin Act, enacted via Bill C-15 with Royal Assent 26 Mar 2026 but not yet in force), and Switzerland (FINMA's "same business, same risks, same rules" applied through banking/DLT/AML law; FinIA Payment Institution reform still proposed).
- Band 3 — Emerging Dedicated (7 jurisdictions): Brazil (Law 14,478/2022 + BCB Resolutions 519/520/521, FX-classified, phased through 2028), Australia (Corporations Act + ASIC guidance, with the dedicated Tranche 1 PSP regime in exposure draft), South Korea (VAUPA baseline plus the DABA stablecoin bill, which remains a pending bill — introduced 10 Jun 2025, re-proposed/consolidated 8 Apr 2026, review pushed to H2 2026), Turkey (CASP licensing under Law No. 7518, no issuance regime), Nigeria (ISA 2025 with a live cNGN whose issuer was admitted to test under the RI/ARIP track, not granted an AIP, on 29 Aug 2024), and South Africa (CASP/AML frameworks operational, stablecoin-issuer regulation at IFWG discussion-paper stage). Bermuda sits at Band 1 (Comprehensive Dedicated) via DABA + SCPS Guidance.
- Band 5 — Restrictive (1 jurisdiction): India (no stablecoin statute or licensing pathway; RBI opposition plus a 30% tax + 1% TDS create de facto discouragement, though not a formal prohibition).
Reserve and redemption convergence. Of the jurisdictions with enacted or proposed reserve rules, full 1:1 (or 100%) backing is the dominant standard — explicitly required in the US, EU, UK, Hong Kong, Singapore, Bahrain, UAE, Canada (federal Act), Bermuda (value parity), and Japan (fund-transfer/trust issuers), and proposed in Australia and South Korea (pending DABA). Brazil is the notable outlier: it has no standalone statutory 1:1 reserve regime, relying instead on FX classification plus proof-of-reserves certification under Instruction 701/2026. Par-value redemption rights track the same set, with next-business-day or short fixed windows in the UK (next business day), Hong Kong (one business day), UAE/CBUAE (next business day), Singapore (5 business days), and Bahrain (5 business days).
Algorithmic stablecoins. No jurisdiction in the set actively welcomes purely algorithmic stablecoins. Brazil bans them outright; the UAE strictly prohibits issuance, service, and promotion. The EU, US, UK, Hong Kong, Singapore, Japan, Bahrain, South Korea (pending), and Canada all exclude them from their dedicated frameworks (either by definition or by imposing reserve requirements they cannot meet). The post-Terra/LUNA (May 2022) collapse is the explicit driver across multiple regimes, reinforced by Do Kwon's 15-year sentence (11 Dec 2025) and the $4.47B Terraform settlement.
CBDC posture. Most jurisdictions position stablecoins and CBDCs as complementary rather than competitive — the UAE (Digital Dirham, retail phase launched Dec 2025), Nigeria (eNaira), Brazil (Drex, now pivoted off-blockchain), and Singapore (wholesale pilots) explicitly frame them this way. India stands apart, with the RBI prioritising the e-rupee as a strategic alternative to private stablecoins. The US explicitly excludes any CBDC from the GENIUS Act's scope.
Abbreviations
| Abbreviation | Full Name |
|---|---|
| ACF | Authorised Cryptoasset Firm (UK) |
| ADGM | Abu Dhabi Global Market |
| AML | Anti-Money Laundering |
| APRA | Australian Prudential Regulation Authority |
| APTCP | Act on Prevention of Transfer of Criminal Proceeds (Japan) |
| ART | Asset-Referenced Token (EU/MiCA) |
| ASIC | Australian Securities and Investments Commission |
| BCB | Banco Central do Brasil |
| BMA | Bermuda Monetary Authority |
| BoC | Bank of Canada |
| BoE | Bank of England |
| BSC | Bahraini Joint Stock Company |
| CARF | Crypto-Asset Reporting Framework (OECD) |
| CASP | Crypto Asset Service Provider |
| CBB | Central Bank of Bahrain |
| CBRT | Central Bank of Republic of Turkey |
| CBUAE | Central Bank of the UAE |
| CGT | Capital Gains Tax |
| CMA | Capital Markets Authority (UAE, formerly SCA) |
| CMB | Capital Markets Board (Turkey) |
| CRA | Crypto-Asset Module (Bahrain) / Canada Revenue Agency |
| CSA | Canadian Securities Administrators |
| DABA | Digital Asset Business Act (Bermuda) / Digital Asset Basic Act (South Korea) |
| DAX | Digital Asset Exchange (Nigeria) |
| DFSA | Dubai Financial Services Authority |
| DPT | Digital Payment Token (Singapore) / Dirham Payment Token (UAE) |
| DTSP | Digital Token Service Provider (Singapore) |
| EBA | European Banking Authority |
| EMI | Electronic Money Institution |
| EMT | Electronic Money Token (EU/MiCA) |
| EPI | Electronic Payment Instrument (Japan) |
| EPIESP | EPI Exchange Service Provider (Japan) |
| FATF | Financial Action Task Force |
| FCA | Financial Conduct Authority (UK) |
| FDIC | Federal Deposit Insurance Corporation (US) |
| FINMA | Swiss Financial Market Supervisory Authority |
| FIU | Financial Intelligence Unit |
| FRS | Fiat-Referenced Stablecoin (Hong Kong) |
| FRT | Fiat-Referenced Token (ADGM) |
| FRVA | Fiat-Referenced Virtual Asset (VARA) |
| FSB | Financial Stability Board |
| FSC | Financial Services Commission (South Korea) |
| FSCA | Financial Sector Conduct Authority (South Africa) |
| FSRA | Financial Services Regulatory Authority (ADGM) |
| HKMA | Hong Kong Monetary Authority |
| HQLA | High-Quality Liquid Assets |
| ISA | Investments and Securities Act (Nigeria) |
| JFSA | Japan Financial Services Agency |
| JVCEA | Japan Virtual and Crypto Assets Exchange Association |
| KoFIU | Korea Financial Intelligence Unit |
| MAS | Monetary Authority of Singapore |
| MiCA | Markets in Crypto-Assets Regulation (EU) |
| MLR | Money Laundering Regulations (UK) |
| MMF | Money Market Fund |
| MPI | Major Payment Institution (Singapore) |
| MSB | Money Services Business |
| NCA | National Crime Agency (UK) / National Competent Authority (EU) |
| OCC | Office of the Comptroller of the Currency (US) |
| PPSI | Permitted Payment Stablecoin Issuer (US) |
| PSA | Payment Services Act |
| PTSR | Payment Token Services Regulation (UAE) |
| SCRC | Stablecoin Certification Review Committee (US) |
| SCS | Single-Currency Stablecoin (Singapore) |
| SEC | Securities and Exchange Commission |
| SIO | Stablecoin Issuance and Offering (Bahrain) |
| SM&CR | Senior Managers and Certification Regime (UK) |
| SPSAV | Sociedade Prestadora de Serviços de Ativos Virtuais (Brazil) |
| SRO | Self-Regulatory Organisation |
| STR | Suspicious Transaction Report |
| TDS | Tax Deducted at Source (India) |
| TFR | Transfer of Funds Regulation (EU) |
| VARA | Virtual Assets Regulatory Authority (Dubai) |
| VASP | Virtual Asset Service Provider |
| VAUPA | Virtual Asset Users Protection Act (South Korea) |
| VDA | Virtual Digital Asset (India) |
| VRCA | Value-Referenced Crypto Asset (Canada) |
Verification Notes
This document is a faithful mirror of the canonical per-jurisdiction fact matrix (.claude/stablecoin-fact-matrix.json) as of the modified date. Every table cell maps directly to a matrix field (Table 1 → t1, Table 2 → t2, ..., Table 10 → t10); no fact appears here that is not in the matrix. Cells reading "Not verified" reflect a field the matrix marks NOT VERIFIED (i.e., the underlying source files contain no verified value), and are deliberately not filled with inference. "X of N" aggregates and archetype/band assignments in the Cross-Cutting Key Takeaways are derived from the matrix spectrum_position fields.
Corrections folded in on this refresh pass:
- Hong Kong: Stablecoins Ordinance is Cap. 656 (not 636); first two issuer licences (Anchorpoint FRS01, HSBC FRS02) granted 10 Apr 2026.
- Canada: the Stablecoin Act is enacted via Bill C-15 (Royal Assent 26 Mar 2026) but not yet in force (in-force date set by Order in Council); framework anticipated 2027.
- Japan: the PSA Amendment Act 2025 takes effect on the single date of 1 June 2026 (per the FSA Cabinet Order published 22 May 2026) — there is no separate "13 June operational deadline" (13 Jun 2025 was the promulgation date of the amendment).
- United States: GENIUS Act implementing NPRMs advanced Feb–May 2026 (OCC comprehensive NPRM Feb 25; FDIC prudential NPRM Apr 7; FinCEN/OFAC joint AML/sanctions NPRM Apr 8; FDIC illicit-finance NPRM May 22; NCUA proposed rule Feb 11), and Tether launched USAT (GENIUS-track) via Anchorage Digital Bank on 27 Jan 2026.
- South Korea: DABA is a pending bill (introduced 10 Jun 2025, re-proposed/consolidated 8 Apr 2026, review pushed to H2 2026) — not enacted; all DABA-derived figures are marked proposed/pending.
- Nigeria: the cNGN issuer (WrappedCBDC) was admitted to test under the RI/ARIP track on 29 Aug 2024 — it was not granted an Approval-in-Principle (AIP).
- Bahrain: AX Coin received the first SIO in-principle approval 28 Jan 2026 and the first full issuer licence (AX Coin Bahrain B.S.C.) 3 Jun 2026.
Per the source-quality policy for this domain, no Wikipedia, Reddit, Quora, X/Twitter, or Medium citations are used; all facts trace to the matrix, which itself draws on primary regulatory and official sources.