Stablecoin Regulatory Guidance Framework

A Comprehensive Reference for National Regulators

Version: 1.1 Date: June 2026 Jurisdictions Covered: 18 countries + 6 international bodies Purpose: To provide national regulators with an evidence-based framework for designing, implementing, or improving stablecoin regulatory regimes.

Table of Contents

Part I: Context and Foundations

1. Executive Summary
2. Why This Document Exists
3. The Current Global Landscape
4. International Organization Positions

Part II: Regulatory Dimensions 5. Issuance Licensing and Authorization 6. Reserve Requirements and Asset Backing 7. Redemption Rights and Holder Protection 8. Systemic Risk Designation 9. AML/KYC Compliance 10. Taxation 11. Payment System Integration 12. Algorithmic Stablecoin Regulation

Part III: Evidence and Outcomes 13. What Works and What Doesn't 14. Country Comparison Overview

Part IV: Implementation 15. Implementation Roadmap 16. Country Profile Decision Matrix

Appendices A. Global Regulatory Comparison Tables B. Source Index C. Verification Notes

Part I: Context and Foundations

1. Executive Summary

Stablecoins have moved beyond speculative crypto trading into payment infrastructure -- card network settlement (Visa, Mastercard), government fee collection (Bermuda, UAE), cross-border remittances, and institutional settlement (Japan's megabank initiative). This transition demands regulatory frameworks commensurate with the systemic role stablecoins now play.

This document synthesises regulation across 18 national jurisdictions and 6 international standard-setting bodies into a single evidence-based reference for regulators. It is a navigation document: each section summarises global approaches, identifies what works and what does not, and links to dedicated analyses for deeper examination. It is not a model law, a compliance manual, or an endorsement of any particular jurisdiction's approach.

The Regulatory Spectrum. Jurisdictions fall on a six-position spectrum of regulatory maturity. The evidence consistently shows that Positions 1 and 2 produce the best outcomes across market growth, consumer protection, financial stability, and international standards compliance.

Seven Non-Negotiable Elements. Every effective stablecoin framework in the studied jurisdictions includes these elements. Their absence correlates with regulatory failure:

1. Issuance licensing -- A defined authorization pathway for stablecoin issuers, whether through banking licenses, dedicated permits, or equivalent mechanisms
2. 100% reserve backing in high-quality liquid assets -- The universal standard across all Position 1-2 jurisdictions; no jurisdiction with a weaker standard has achieved positive regulatory outcomes
3. Statutory par-value redemption within a defined timeframe -- Ranging from same-day/next-business-day (EU EMTs, UAE, Hong Kong) to T+5 (Singapore, Bahrain), with next-business-day emerging as the modal standard
4. Reserve segregation with insolvency ring-fencing -- Reserves must be legally separated from the issuer's estate and prioritized for holder claims in bankruptcy
5. AML/KYC compliance including Travel Rule implementation -- FATF alignment is non-negotiable; grey-listing risk affects the entire financial sector
6. Mandatory disclosure through white papers or equivalent instruments -- Covering reserve composition, redemption procedures, risk factors, and governance
7. Algorithmic stablecoin exclusion or prohibition -- The global consensus post-Terra/LUNA is that pure algorithmic models cannot meet stabilization requirements

Key Finding. Comprehensive frameworks (Positions 1-2) produce better outcomes than either restrictive regimes or regulatory absence. Position 1 jurisdictions attracted major institutional participants: Japan's megabanks and JPYC, Singapore's Paxos and StraitsX, Hong Kong's HSBC and Anchorpoint (first two FRS licences, April 2026), the UAE's bank-backed AED issuers, and Bahrain's first SIO licensee (AX Coin, June 2026). Position 3-5 jurisdictions show stablecoin usage but limited domestic issuance under a complete prudential regime -- users depend substantially on foreign-issued tokens without full local consumer protection.

What This Document Is Not. This is not a model law or legislative template. It does not recommend a single regulatory approach. It does not constitute legal advice. Jurisdictions must adapt these findings to their domestic legal traditions, institutional capacity, market conditions, and policy priorities.

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2. Why This Document Exists

Three developments create urgency for stablecoin regulation:

Market scale. The stablecoin market has grown from approximately $5 billion in early 2020 to a multi-hundred-billion-dollar sector. USDT and USDC dominate circulation and transaction volume; stablecoins are no longer a niche crypto instrument -- they are infrastructure. In the United States, Tether launched USAT (a GENIUS Act-compliant US stablecoin via Anchorage Digital Bank) in January 2026, coexisting with the global USDT.

Payment system integration. Card networks (Visa, Mastercard) and payment providers (PayPal PYUSD, Stripe) have embedded stablecoins in mainstream payment rails. Bermuda became the first national government to accept tax payments in USDC and is piloting merchant USDC payments. The UAE has live AED-pegged payment tokens at point-of-sale (AE Coin, January 2026). These integrations embed stablecoins in critical payment infrastructure, making regulatory gaps systemically consequential.

Post-crisis lessons. The Terra/LUNA collapse (May 2022) erased tens of billions and triggered cascading bankruptcies across the crypto sector; Do Kwon was sentenced to 15 years in December 2025 and Terraform settled with the SEC for $4.47B. The USDC/SVB depeg (March 2023) demonstrated that even well-reserved stablecoins face contagion from traditional banking failures. The EU's USDT delisting disrupted European trading markets. Each crisis exposed specific regulatory gaps that this framework addresses.

The FSB's October 2025 Thematic Peer Review confirmed that "significant gaps and inconsistencies" persist in stablecoin regulation globally. This document provides the evidence base for closing those gaps.

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3. The Current Global Landscape

The 18 jurisdictions studied span every major financial market and regulatory tradition. The table below summarizes each jurisdiction's position on the regulatory spectrum, primary regulator, and key statute. For the full placement analysis and outcome evidence, see Regulatory Spectrum.

Spectrum tally (derived from per-jurisdiction classifications): Position 1 -- 8 jurisdictions (EU, Japan, Hong Kong, Singapore, UAE, Bermuda, Bahrain, UK); Position 2 -- 3 (US, Switzerland, Canada); Position 3 -- 6 (Brazil, South Korea, Australia, Nigeria, Turkey, South Africa); Position 5 -- 1 (India). No studied jurisdiction sits at Position 4 or 6.

Key trend: The global trajectory is convergence toward Position 1. Eight jurisdictions now have stablecoin-specific frameworks enacted or operational -- the EU and Japan (the early movers), joined by Hong Kong, Singapore, the UAE, Bermuda, Bahrain, and the UK (regime made February 2026, commencing October 2027). The US (GENIUS Act, effective by January 2027) and Canada (Stablecoin Act, enacted March 2026 but not yet in force) are integrated frameworks moving toward full operation, while a further cohort (Brazil, South Korea, Australia, Nigeria, Turkey, South Africa) is actively building dedicated rules.

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4. International Organization Positions

Six international bodies collectively define global regulatory expectations for stablecoins. No single body provides a complete framework; the architecture is composite. For the full analysis of how these standards interact, overlap, and create gaps, see International Standards Synthesis.

The EU and Singapore are the most closely aligned with the full suite of international standards. The primary global gap is Basel d545 implementation, which was extended to January 1, 2026 and remains incomplete in several major banking jurisdictions. Recovery and resolution planning is covered only by the FSB (Recommendation 7), leaving a significant gap in binding international requirements. Cross-border supervisory cooperation is beginning to fill in bilaterally -- the EBA and NYDFS signed a non-binding MoU on cross-border stablecoin supervision in June 2026.

Part II: Regulatory Dimensions

5. Issuance Licensing and Authorization

Licensing models fall into six types: bank-only (Japan's strictest form), bank-plus-qualified-nonbank (US GENIUS Act PPSI, Hong Kong), dedicated stablecoin license (Singapore SCS, UAE CBUAE, Bahrain SIO), integrated digital asset license (Bermuda DABA), existing financial services adaptation (Switzerland, EU MiCA EMI pathway), and sandbox-to-license pipelines (Hong Kong, Bahrain, Nigeria). For the full comparative analysis of all 18 jurisdictions, see Issuance Licensing.

Recommended tiered framework:

Capital requirements across jurisdictions range from BHD 250,000 (~$663K, Bahrain) to bank-equivalent requirements (Japan banks, Switzerland full banking licence). The EU's ART capital formula -- the greater of EUR 350,000, 2% of average reserves, or 25% of fixed overheads -- provides a proportionate scaling model. The US GENIUS Act establishes a Permitted Payment Stablecoin Issuer (PPSI) pathway across bank subsidiaries, OCC-supervised nonbanks, and state-qualified issuers, with the OCC's February 2026 NPRM proposing a $5M de novo capital floor.

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6. Reserve Requirements and Asset Backing

The 100% reserve backing requirement is the single most consistent element across all jurisdictions with dedicated stablecoin frameworks. No Position 1 or 2 jurisdiction permits fractional reserve stablecoin issuance. Qualifying assets converge around cash, short-term government securities (maturities ranging from 3 months to 1 year), central bank deposits, and insured bank deposits. The debate centers on composition ratios and maturity limits rather than the 100% backing principle itself. For the full reserve analysis, see Reserve Requirements.

Key data points: Switzerland's Sygnum DCHF and SIX tCHF are backed by Swiss National Bank sight deposits -- the highest quality reserve asset globally. The UK BoE initially proposed 40% of systemic stablecoin reserves at the central bank (Nov 2025), a figure now under downward revision following industry and parliamentary pushback. The US GENIUS Act limits T-bill maturities to 93 days. Singapore requires monthly independent attestation plus annual audit. The UAE imposes the most granular reserve oversight -- CBUAE daily reconciliation and reporting, monthly external-auditor confirmation, and bi-annual audits.

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7. Redemption Rights and Holder Protection

Par-value redemption at face value is the emerging global norm -- the large majority of jurisdictions with operational or enacted frameworks require it for single-currency fiat-backed stablecoins. Timeframes range from same-day/at-any-time (EU EMTs) to next-business-day (Hong Kong, UK, UAE CBUAE) to T+5 (Singapore, Bahrain). The EU's absolute prohibition on EMT redemption fees is unique globally. Japan is the only jurisdiction extending deposit insurance to bank-issued stablecoins (JPY 10M per depositor). For the full analysis, see Redemption Rights.

The sharpest unresolved question is insolvency treatment. The US GENIUS Act excludes reserves from the bankruptcy estate, but legal analysis has questioned whether holders' practical distribution priority matches the statutory intent. The EU's approach -- reserves used "exclusively for the benefit of holders" with no claims from general creditors (MiCA Art. 37) -- provides the strongest structural protection, and the UAE's CBUAE legal ring-fencing gives consumers priority claims on reserves in insolvency.

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8. Systemic Risk Designation

No stablecoin has been formally designated as systemically important in any jurisdiction as of June 2026. Approaches fall into three models: threshold-based (EU MiCA significant ART/EMT: at least 3 of >10M holders, >EUR 5B issued/reserve, >2.5M daily transactions, >EUR 500M daily value), discretionary (UK: HMT recognition of systemic stablecoins, then BoE supervision), and size-based escalation (US GENIUS Act: $10B consolidated outstanding triggers transition from state to federal oversight). For the full analysis, see Systemic Risk.

MiCA's quantitative threshold model provides the highest legal certainty. The UK's dual-regulator model (FCA for conduct, BoE for systemic) creates institutional depth, though the BoE's individual holding limits are being abandoned in favour of temporary aggregate issuance caps (May 2026). The US $10B escalation creates proportionate oversight. The critical gap globally is recovery and resolution planning -- the FSB's October 2025 peer review confirmed most frameworks lack it.

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9. AML/KYC Compliance

FATF standards provide the universal baseline. All 18 studied jurisdictions have AML frameworks covering crypto-asset activities. The Travel Rule is the primary implementation frontier. Japan, Singapore, and South Korea lead with zero de minimis thresholds (all transactions); South Korea moved to a zero-threshold travel rule covering stablecoins and unhosted wallets in early 2026. Switzerland applies a stricter-than-FATF CHF 1,000 threshold. The EU's Transfer of Funds Regulation applies to all crypto transfers with no de minimis (enforceable since 30 Dec 2024). The US GENIUS Act treats issuers as BSA financial institutions, with a FinCEN/OFAC joint NPRM (April 2026) mandating AML/CFT and sanctions-compliance programs. For the full analysis, see AML/KYC Compliance.

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10. Taxation

Tax treatment is the most fragmented regulatory dimension. Many jurisdictions classify stablecoins as property, making every disposition a potentially taxable event -- even when gains are near-zero. This creates compliance burdens for payment use cases. Effective approaches include: VAT/GST exemption (EU per CJEU Hedqvist, Singapore, UAE, Australia, Japan), zero capital gains tax on private holdings (Hong Kong, Singapore, Switzerland, Bahrain, UAE), and broker reporting for stablecoin transactions (US Form 1099-DA, with de minimis non-reporting for qualified stablecoin sales under $10,000/yr). India's 30% flat tax with no loss offset and 1% TDS -- retained unchanged in the 2026 Union Budget -- has driven the bulk of crypto trading offshore. OECD CARF reporting is spreading rapidly (EU DAC8, Canada, UK, Nigeria from 1 Jan 2026; Switzerland from 2027). For the full analysis, see Taxation Frameworks.

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11. Payment System Integration

Payment integration has advanced furthest in jurisdictions with clear licensing regimes. Bermuda is the world's first national government to accept stablecoin tax payments and is expanding merchant USDC acceptance. The UAE has live AED-pegged payment tokens at point-of-sale (AE Coin, January 2026) and a complementary Digital Dirham CBDC (retail phase launched December 2025). Japan's EPI framework, Singapore's licensed issuers, and the US GENIUS Act all provide clear payment pathways; the UK reversed its earlier position in April 2026 to bring UK-issued qualifying stablecoins used for payments into the regulated payments perimeter. Card network integration (Visa, Mastercard, PayPal PYUSD) is embedding stablecoins in existing payment infrastructure. CBDCs and stablecoins are primarily complementary, not competitive, in jurisdictions with clear frameworks. Brazil is a notable counter-current: Resolution 561/2026 bans virtual-asset settlement of the offshore leg of regulated eFX cross-border payments (effective 1 Oct 2026). For the full analysis, see Payment System Integration.

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12. Algorithmic Stablecoin Regulation

The global consensus post-Terra/LUNA is unambiguous: pure algorithmic stablecoins cannot meet stabilization requirements. The FSB states they "do not meet Recommendation 9." The Basel Committee classifies them as Group 2b (1,250% risk weight). Jurisdictions respond through explicit prohibition (Brazil bans purely algorithmic pegs; UAE CBUAE strictly prohibits issuance, service, or promotion), exclusion from dedicated frameworks (EU MiCA Recital 41 excludes supply-adjusting algorithmic tokens; US GENIUS Act excludes them from "payment stablecoin"; Singapore excludes from SCS; Hong Kong limits the Ordinance to fiat-referenced stablecoins; Japan treats them as crypto-assets, not EPIs), or full-backing requirements that function as de facto exclusion (South Korea's pending DABA would require 100%+ asset backing and guaranteed redemption). Crypto-collateralized stablecoins (e.g., DAI) occupy a regulatory grey zone. For the full analysis, see Algorithmic Stablecoins.

Part III: Evidence and Outcomes

13. What Works and What Doesn't

The evidence across 18 jurisdictions and 6 international bodies identifies clear patterns. For the full evidence assessment with verified outcomes, see What Works & What Doesn't.

Top 3 Failures:

1. India's punitive taxation. The 30% flat tax with no loss offset and 1% TDS makes no distinction between speculative crypto and near-zero-gain stablecoins. Verified outcome: the bulk of Indian crypto trading migrated offshore; the framework was retained unchanged in the 2026 Union Budget despite collection shortfalls. RBI's December 2025 Financial Stability Report concluded stablecoin "risks outweigh purported benefits."

2. US regulatory fragmentation (pre-GENIUS Act). Multiple agencies (SEC, CFTC, FinCEN, OCC, state regulators) asserted overlapping claims without statutory clarity from 2020 to mid-2025. Verified outcome: enforcement uncertainty (Paxos/BUSD, Binance) chilled domestic issuance. The GENIUS Act (enacted July 2025) was explicitly designed to resolve this, and implementing NPRMs from the OCC, FDIC, and FinCEN/OFAC advanced through April-May 2026.

3. EU USDT delisting disruption. MiCA's compliance deadlines forced delisting of USDT from EU-regulated exchanges (late 2024 to early 2025) without adequate transition mechanisms. Verified outcome: trading liquidity contracted on EU platforms; activity migrated to non-EU venues. Circle gained EU market share, but overall European stablecoin volumes fell relative to global growth.

Top 3 Successes:

1. Singapore's SCS framework. The "MAS-regulated stablecoin" designation created a positive opt-in label rather than a negative prohibition. Verified outcome: Paxos and StraitsX received full MPI licenses; USDG launched from Singapore via the Global Dollar Network; institutional adoption accelerated.

2. EU MiCA legal clarity. Despite USDT delisting friction, MiCA provided the world's most comprehensive stablecoin framework. Verified outcome: Circle obtained EMI authorization (July 2024); a euro-stablecoin consortium (Qivalis) formed and reportedly expanded to 37 banks across 15 countries with launch targeted H2 2026.

3. Bermuda's early-mover advantage. DABA (2018) was the world's first comprehensive digital asset framework, now supplemented by stablecoin-specific SCPS Guidance (2024). Verified outcome: Circle operates from Bermuda; the government is piloting USDC-based payments and merchant acceptance, pursuing a sovereign-grade "Bermuda Digital Dollar" via a Stellar partnership.

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14. Country Comparison Overview

The research includes detailed side-by-side comparison tables across ten regulatory dimensions for all 18 jurisdictions: legal status, issuance licensing, reserve requirements, redemption rights, systemic risk, AML/KYC, taxation, algorithmic treatment, payment integration, and international standards compliance. These tables enable direct dimension-by-dimension comparison across all studied jurisdictions. See Country Comparison Tables for the full tables.

Part IV: Implementation

15. Implementation Roadmap

Building a stablecoin regulatory framework from scratch is a multi-year undertaking. The evidence from jurisdictions that have completed this journey -- EU (MiCA), Singapore (SCS), Hong Kong (Stablecoins Ordinance), UAE (PTSR/VARA/ADGM), Bermuda (DABA/SCPS), Bahrain (SIO Module) -- supports a three-year phased approach. For the full implementation guide with country precedents, institutional design, and stakeholder consultation guidance, see Implementation Guide.

Year 1 -- Foundation. Establish legal certainty by defining stablecoins under domestic law. Implement FATF-compliant AML/KYC framework (non-negotiable due to grey-listing risk). Launch regulatory sandbox for stablecoin issuers. Conduct market assessment and stakeholder consultation. Country precedents: Hong Kong launched its sandbox in March 2024; Bahrain's CRA Module (2019) preceded dedicated stablecoin rules; Nigeria's ARIP/RI track provided a controlled pathway.

Year 2 -- Enhancement. Enact or finalize stablecoin-specific regulation covering issuance licensing, reserve requirements, redemption rights, and disclosure. Begin licensing and onboarding issuers. Implement Travel Rule. Develop systemic risk assessment criteria. Country precedents: Singapore moved from SCS policy finalization (August 2023) to MPI licenses (July 2024); UAE operationalized PTSR within roughly 12 months; Bahrain moved from SIO Module (July 2025) to first full issuer licence (June 2026).

Year 3 -- Maturity. Activate systemic risk designation framework. Achieve full international standards alignment (FSB, IOSCO, CPMI-IOSCO, Basel). Develop cross-border mutual recognition arrangements (e.g., the EBA-NYDFS MoU, June 2026). Address CBDC coexistence. Country precedents: EU MiCA's full regime operationalized over roughly 18 months; Japan's framework matured through iterative PSA amendments (2022, and the 2025 amendment effective 1 June 2026).

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16. Country Profile Decision Matrix

Jurisdictions approaching stablecoin regulation face different starting conditions. The following profiles map country characteristics to recommended regulatory approaches, based on verified outcomes from comparable jurisdictions.

Profile 1: Large economy, strong banking sector. Recommended approach: Integrated framework leveraging existing banking regulation with stablecoin-specific overlay. Model: UK (FCA/BoE dual-track), US (GENIUS Act PPSI with OCC national trust bank charters). Rationale: Existing prudential infrastructure can be extended rather than rebuilt. Bank-issued stablecoins leverage existing trust and regulatory relationships.

Profile 2: Small financial hub seeking competitive advantage. Recommended approach: Dedicated early-mover framework with fast licensing and clear regulatory perimeter. Model: Singapore (SCS framework), Bermuda (DABA), Bahrain (SIO Module, 60-day decision window). Rationale: Speed-to-market and regulatory clarity attract international issuers. Singapore attracted Paxos and StraitsX; Bermuda attracted Circle. The "regulated label" approach creates positive incentives without market restriction.

Profile 3: Multi-jurisdictional or federal system. Recommended approach: Clear federal preemption with tiered state/federal oversight. Model: US GENIUS Act ($10B threshold for state-to-federal transition). Rationale: Without jurisdictional clarity, agencies compete and issuers face contradictory requirements. The pre-GENIUS Act US experience demonstrates the cost of fragmentation. Canada's Stablecoin Act (Bank of Canada supervision, enacted March 2026 but not yet in force) and the EU's MiCA passporting both address this challenge.

Profile 4: Developing economy, limited regulatory capacity. Recommended approach: Sandbox-first with phased implementation. Model: Hong Kong (sandbox March 2024 to Ordinance August 2025), Bahrain (CRA Module 2019 to SIO Module 2025), Nigeria (ARIP/RI track; cNGN issuer admitted to test under the ARIP/RI regime). Rationale: Sandboxes build regulatory knowledge before committing to a full framework. They allow capacity building and reveal implementation challenges before rules are finalized.

Profile 5: CBDC-priority economy. Recommended approach: Complementary framework explicitly defining the stablecoin-CBDC relationship. Model: UAE (private payment tokens for commercial payments, Digital Dirham for retail/wholesale settlement), Brazil (Drex repositioned as institutional settlement infrastructure, private stablecoins within the FX perimeter). Rationale: Treating CBDCs and stablecoins as competitive (India's approach) creates unresolved policy tension and benefits neither. The evidence shows they serve complementary functions when the regulatory framework explicitly defines each instrument's role.

Appendices

A. Global Regulatory Comparison Tables

The full side-by-side comparison tables covering all 18 jurisdictions across ten regulatory dimensions are maintained in Country Comparison Tables. Tables cover: legal status and institutional design, issuance licensing requirements, reserve requirements, redemption rights, systemic risk designation, AML/KYC requirements, taxation, algorithmic stablecoin treatment, payment system integration, and international standards compliance.

B. Source Index

This research draws on the following source categories across all section files:

• Government legislation and regulation: Primary legal texts from 18 jurisdictions including enacted statutes, regulatory instruments, central bank guidance, and consultation papers (~60 primary sources)
• Regulatory guidance and supervisory documents: FINMA Guidance, FCA consultation papers, NYDFS industry letters, MAS media releases, HKMA notices, CBUAE/VARA/ADGM rulebooks (~25 sources)
• International organization reports: FSB High-level Recommendations, FATF Targeted Updates, IOSCO Policy Recommendations, CPMI-IOSCO PFMI guidance, IMF Elements of Effective Policies, Basel d545 standard (~15 primary documents)
• Court decisions and enforcement actions: Terraform SEC settlement ($4.47B), Do Kwon sentencing (15 years), Binance multinational enforcement, NYDFS/Paxos settlement, FINMA investigations (~20 enforcement actions cited)
• Law firm and industry analyses: Latham & Watkins, Paul Hastings, Davis Polk, Morgan Lewis, Sidley Austin, Norton Rose Fulbright, and other major firms providing legislative analysis (~40 secondary sources)

Each section file contains its own detailed verification notes with specific URLs and source attributions.

C. Verification Notes

This research was verified against the canonical per-jurisdiction fact matrix as of June 4, 2026. The following items warrant particular caution:

• GENIUS Act implementing regulations are advancing but not finalized. The OCC issued a comprehensive NPRM (Feb 25, 2026); the FDIC approved a prudential NPRM proposing two-business-day redemption (Apr 7, 2026) and an illicit-finance NPRM (May 22, 2026); and Treasury (FinCEN/OFAC) issued a joint AML/CFT and sanctions NPRM (Apr 8, 2026). The Act becomes effective on the earlier of January 18, 2027 or 120 days after final rules. Specific federal requirements remain subject to the rulemaking process. Tether launched USAT (a GENIUS-compliant issuance via Anchorage Digital Bank) in January 2026.
• Hong Kong Stablecoins Ordinance is Cap. 656 (in force since 1 August 2025); the first two issuer licences (Anchorpoint FRS01, HSBC FRS02) were granted on 10 April 2026.
• Japan's PSA Amendment Act 2025 (enacted 6 June 2025) takes effect on 1 June 2026 as a single enforcement date (per the FSA Cabinet Order published 22 May 2026).
• UK regime (Cryptoassets Regulations 2026, FCA CP25/14, BoE systemic consultation) was made by Parliament on 4 February 2026 but largely commences 25 October 2027. BoE reserve and holding-limit proposals are under revision; provisions described should be read as proposed where not yet final.
• South Korea DABA is a pending bill -- introduced 10 June 2025, re-proposed/consolidated by the ruling party in April 2026, with review pushed into H2 2026. It is not enacted; the operative law remains VAUPA.
• Canada Stablecoin Act (Division 45, Bill C-15) received Royal Assent on 26 March 2026 -- it is enacted but not yet in force (in-force date set by Order in Council; draft regulations not yet published as of June 2026).
• Nigeria cNGN was launched under SEC/CBN supervision; its issuer was admitted to test under the ARIP/RI regime (29 August 2024), not granted a separate Approval-in-Principle. Continuous proof-of-reserve has been flagged as a gap.
• Singapore SCS legislation is not yet enacted; the dedicated framework operates as MAS policy layered on the PSA, with legislative codification expected mid-2026.
• Switzerland FinIA stablecoin amendments remain proposed (consultation closed 6 February 2026); a parliamentary dispatch is expected H2 2026 at the earliest.
• GENIUS Act insolvency priority for stablecoin holders has been questioned by legal scholars. While the Act excludes reserves from the bankruptcy estate, practical distribution priority may differ from the statutory intent; the matrix records this dimension as NOT VERIFIED for the US.

Where the matrix records a fact as NOT VERIFIED, this document does not assert it. All individual section files contain their own detailed verification notes.

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For the parallel analysis of crypto mining regulation, see Crypto Mining Regulatory Guidance.