Original Article Title: "Stablecoin Decoupling in Progress: In-Depth Analysis of the Regulatory Race of Stablecoin Policies in 12 Countries"
Original Article Author: Fairy, ChainCatcher

The decoupling effect of stablecoins is continuing to magnify.

From the frequently appearing topics on the TikTok trending list to the content creation shift of traditional financial bloggers, and to the proactive inquiries from relatives and neighbors, stablecoins seem to have become a pervasive everyday social buzzword.

At the same time, there has been a crucial turning point on the global policy front. Over the past year, many countries' attitudes towards stablecoins have shifted from cautious observation to acceptance: Hong Kong's "Stablecoin Ordinance" is about to be implemented, the EU's MiCA regulation has officially landed, and the US has passed the "GENIUS Act." Stablecoins are quietly levering the foundation of the global monetary system.

This article will systematically review the latest developments in stablecoin regulation in various countries, analyzing the underlying logic and strategic implications of this financial transformation.

Global Stablecoin Regulatory Landscape at a Glance

Analyzing the Evolution of Stablecoin Policies in Twelve Core Global Markets

United States: State-Federal Divide, Competitive Layout

Policy Progress Speed: ★★★★

The development of stablecoins in the United States has presented a dual-track progression of "federal + state-level" advancement. On the one hand, the federal government is accelerating the establishment of a unified regulatory framework at the legislative level; on the other hand, various states are taking the lead to explore and push forward the landing of institutional arrangements.

At the state level, many places have already implemented specific regulations and regulatory frameworks:

Wyoming passed the "Wyoming Stablecoin Act" in 2023, establishing the "Wyoming Stablecoin Committee" and planning to issue the state-backed stablecoin WYST on August 20, 2025.

The New York Department of Financial Services required stablecoin issuers to obtain a BitLicense or trust company license in 2018 and comply with strict regulations.

California passed the "Digital Financial Asset Law" (DFAL) in 2023, establishing a comprehensive licensing system, including for stablecoin issuers. DFAL will officially take effect in July 2026.

Regulatory legislation at the federal level is also rapidly advancing:

The "GENIUS Act" was signed into law by Trump on July 19, 2025.

The bill requires: banning the issuance of profit-driven stablecoins, monthly disclosure of reserve composition with audits, CEO and CFO accountability for data accuracy. Issuers may choose federal or state regulation, with small issuers (issuance < $100 billion) having the option to be solely state-regulated.

The STABLE Act was proposed in March 2025, has currently passed the House deliberation, and is awaiting a Senate vote. The draft contents of the bill are largely the same as those of the GENIUS Act.

China: Hong Kong Takes the Lead, Mainland Observes

Policy Progress Speed: Hong Kong★★★★ | Mainland★

Mainland China and Hong Kong have formed a "frontier + domestic" stablecoin regulatory linkage pattern: Hong Kong has taken the lead in establishing a mature regulatory system, accelerating enterprise landing, while the mainland remains cautious at the policy level.

On the Hong Kong side, its Stablecoin Ordinance will officially take effect on August 1, 2025.

Currently, approximately 50 to 60 companies have expressed their application intentions, half of which are payment institutions and the other half are large internet platforms, mostly with a Chinese background. Companies such as JD.com, Standard Chartered, and Ant Group have started relevant preparations, with the industry expecting only 3 to 4 licenses to be issued in the first batch, setting a high admission threshold.

It is reported that the first batch of licenses may adopt an "invitation application system" rather than a unified open application process, with the initial stablecoins mainly pegged to the Hong Kong dollar and the U.S. dollar.

On the mainland side, it has been in a long-term "precautionary suppression" stance in the past, but recently several provinces and cities have shown signals of research on and attention to stablecoins.

On July 7, the Wuxi Municipal Party Committee's reform promotion meeting proposed exploring "stablecoin empowerment for foreign trade development" to expand new digital trade space;

On July 9, the Jinan Municipal People's Government Research Office's official public account released a stablecoin feature article written by Xinhua News Agency;

On July 10, the Shanghai State-owned Assets Supervision and Administration Commission Party Committee held a central group study session to discuss the development trends of cryptocurrency and stablecoins as well as response strategies;

On July 18, the China Industrial Internet Research Institute hosted a "Stablecoin and Industrial Digital Asset Seminar".

South Korea: Shifting Attitudes, Bank Alliances Accelerate Deployment

Policy Progress Speed: ★★★

South Korea is undergoing a transition from "wait-and-see" to "taking action." Against the backdrop of newly elected President Lee Jae-myung's commitment to support the development of a Korean won stablecoin, on June 10, the ruling party of South Korea officially proposed the "Digital Asset Basic Law," aiming to allow local companies with capital exceeding $368,000 to issue stablecoins, marking a loosening of the policy at a governmental level.

Currently, the eight major banks in South Korea are establishing a joint venture company with plans to collectively issue a Korean won stablecoin. Participating institutions include the National Bank of Korea, Shinhan Bank, Woori Bank, NongHyup Bank, Industrial Bank of Korea, Suhyup Bank, as well as the Korean branches of Citi and Standard Chartered. This project is jointly driven by the eight banks, the Open Blockchain and Decentralized Identity Association, and the Financial Supervisory Service, and if approved by regulators, it is expected to go live by the end of this year or early next year.

However, the current regulation is still in an uncertain state. According to 100y.eth, Director of Research at Four Pillars, South Korea is currently experiencing a stablecoin bubble, with no clear guidance on the regulatory front. Financial news outlets report almost daily about banks or companies applying for stablecoin-related trademarks, and the stock prices of related publicly traded companies typically rise by 15%-30% on the day of the news.

Thailand: Policy Opening Up, Cautiously Dipping Toes

Policy Progress Speed: ★★★

Thailand's stablecoin policy has transitioned from early caution to gradually exploring in a cautious manner. As early as 2021, the Bank of Thailand initiated regulatory exploration of stablecoins and issued preliminary guidance. Within this, stablecoins anchored to the Thai Baht are considered "electronic currency," regulated under the "Payment Systems Act," and relevant entities are required to consult with the central bank for approval before issuance; while stablecoins pegged to foreign currencies (such as USDT, USDC) are not prohibited but require further regulation.

The real turning point came in 2024. In August, Thailand established a regulatory sandbox, allowing specific service providers to experiment with cryptocurrencies.

In 2025, the pilot scope accelerated expansion:

In January, the Thai Finance Minister stated at a Securities and Exchange Commission meeting that the government is considering issuing a stablecoin supported by 100 billion Thai Baht in government bonds.

In March, the Securities and Exchange Commission (SEC) of Thailand approved USDT and USDC as tradable assets on regulated exchanges in the country.

In July, the SEC and BOT jointly launched a "national-level crypto sandbox," allowing foreign tourists to convert digital assets (such as USDT, USDC) into Thai Baht through licensed platforms for tourist consumption.

EU: Unified Regulation, Cautious Support

Policy Progress Speed: ★★★★★

The EU's attitude toward stablecoin development can be summed up as "cautious support": fully acknowledging the potential of stablecoins while maintaining a high level of vigilance regarding financial stability, regulatory arbitrage, and money laundering risks.

In June 2023, the EU officially released the Markets in Crypto-Assets Regulation (MiCA), with the core goal of comprehensive regulation of the crypto-asset market. Certain provisions came into effect on June 30, 2024, and the stablecoin-related provisions will be fully implemented by December 30, 2024. This legislation applies to the 27 EU member states and the three countries in the European Economic Area (EEA): Norway, Iceland, and Liechtenstein.

MiCA sets high thresholds for the issuance and operation of stablecoins: issuers must obtain authorization from a member state regulatory authority (such as BaFin in Germany or AMF in France) and establish a legal entity in the EU. For systemically important stablecoins (e.g., those with significant transaction volumes), oversight will be conducted by the European Banking Authority (EBA).

MiCA also stipulates that stablecoins denominated in a currency other than the euro must not exceed 1 million transactions or €200 million in daily trading within any single currency area. If this limit is exceeded, the issuer must suspend the issuance of the stablecoin and submit a remediation plan within 40 working days.

Currently, the EU has issued MiCA licenses to 53 crypto firms, including 14 stablecoin issuers and 39 crypto asset service providers.

Singapore: Early Start, High Standards

Policy Progress Speed: ★★★★★

Singapore is at the forefront of stablecoin regulation. As early as December 2019, Singapore enacted the Payment Services Act, which defined and classified payment service providers.

Subsequently, the Monetary Authority of Singapore (MAS) released a draft Stablecoin Regulatory Framework in December 2022 and initiated public consultations, leading to the official launch of the final version on August 15, 2023. This regulatory framework specifically applies to single-currency stablecoins (SCS) issued in Singapore and pegged to the Singapore Dollar (SGD) or a G10 currency. It is integrated into the regulatory system as a supplementary provision of the Payment Services Act.

MAS has set a high entry threshold, and issuers must meet the following requirements:

The stablecoin issuer's capital shall be no less than 50% of the annual operating expenses or 1 million new yuan;

The stablecoin issuer shall not engage in trading, asset management, collateralization, lending, or other businesses, nor directly hold shares of other legal entities;

The liquidity assets shall meet the scale required for normal asset withdrawals or be higher than 50% of the annual operating expenses.

The reserve assets of the stablecoin issuer can only consist of the following assets with extremely low risk and sufficient liquidity: cash, cash equivalents, bonds with a residual maturity of not more than three months.

Currently, several institutions have applied to MAS for stablecoin issuance qualifications. Among them, StraitsX (issuer of XSGD) and Paxos are considered exemplary cases of being the first to comply with regulations.

United Arab Emirates: Actively Promoting, Dual Track

Policy Progress Speed: ★★★★★

The United Arab Emirates has shown a supportive and open attitude towards stablecoin policies. In June 2024, the Central Bank of the UAE issued the "Payment Token Service Regulation," defining the "payment token" (stablecoin) and its regulatory framework.

As a federal nation composed of seven emirates, the UAE's regulatory system has a distinct "dual-track" feature: the central bank is responsible for regulation at the federal level, while the Dubai International Financial Centre (DIFC) and the Abu Dhabi Global Market (ADGM) act as financial free zones with independent legal systems and regulatory authority.

Compared to the EU's "MiCA" or Hong Kong's "Stablecoin Regulations," the UAE's new regulations have a relatively broad definition of stablecoins but still set certain boundaries:

Prohibition of issuing algorithmic stablecoins and privacy tokens

Stablecoins are not allowed to pay users interest or other rewards tied to holding time

In terms of specific applications, the stablecoin market in the UAE has also shown initial success. In December 2024, AE Coin was approved by CBUAE, becoming the UAE's first fully regulated Dirham stablecoin.

In April 2025, the Abu Dhabi sovereign wealth fund ADQ, the conglomerate IHC, and the UAE's largest asset-size bank First Abu Dhabi Bank jointly announced the launch of a new Dirham-pegged stablecoin.

Japan: Regulation First, Development Yet to Begin

Policy Progress Speed: ★★★★

Japan is at the forefront of stablecoin regulation globally and was the first to establish a basic legislative framework. Its regulatory approach is mainly achieved through improvements to the Payment Services Act (PSA).

In June 2022, the Japanese Diet passed an amended version of the Payment Services Act, which officially took effect in June 2023. The amended law provides a detailed definition of stablecoins, specifies the issuing entities, and lists the licenses required to operate a stablecoin exchange. It restricts the entities that can issue stablecoins to three categories: banks, trust companies, and funds transfer service providers.

In March 2025, the Japanese Financial Services Agency promoted the "2025 Payment Services Act Amendment," which optimizes the stablecoin issuance mechanism. It allows trust-based stablecoins to allocate up to 50% of their reserve assets to specific low-risk instruments such as short-term government bonds or fixed-term deposits. The law also introduces a specialized registration category for crypto intermediaries to lower the barrier to entry for OTC transactions.

Russia: Emphasis on Experimentation, Still Restricts External Use

Policy Progress Speed: ★★

Russia's attitude toward stablecoins has undergone a significant shift in recent years, moving from initial caution or even opposition to limited support. This change is primarily driven by the strategic need for cross-border settlements and an independent financial system under geopolitical pressure.

In 2022, the Central Bank of Russia advocated for a comprehensive ban on cryptocurrencies. However, in July 2024, there was a key policy reversal. The Russian Federal Assembly passed two bills that officially legalized cryptocurrency mining and allowed enterprises approved by the Central Bank to use crypto assets, including stablecoins, for international settlements with foreign partners. However, within the domestic domain, cryptocurrency still cannot be used as a means of payment.

In March 2025, the Central Bank of Russia released a proposal to allow "specially qualified" high-net-worth individuals and certain enterprises to invest in crypto assets during a three-year pilot period, exploring a more transparent and controlled market environment.

Outside the policy context, Ivan Chebeskov, the head of the Digital Financial Assets Department at the Ministry of Finance, publicly stated that Russia should consider issuing its own sovereign stablecoin to align with the evolving trends in the global payment system.

United Kingdom: Regulatory Progress Underway

Policy Progress Speed: ★★

The UK policy is currently at a key juncture transitioning from framework design to legislative implementation. The relevant regulatory framework is based on the "Financial Services and Markets Act 2023," supplemented by secondary regulations and regulatory guidance developed by the Financial Conduct Authority (FCA) and the Bank of England (BoE). This act received Royal Assent on June 29, 2023, for the first time bringing "digital settlement assets" (including stablecoins) into the legal scope of regulated financial activities.

In November 2023, the UK Financial Regulatory Authority published regulatory requirements for companies issuing or custoding fiat-backed stablecoins. The proposed framework will seek to apply several existing regulatory standards that are already applicable to many FCA-authorized entities to the stablecoin activities.

In April 2025, the UK government released a consultation document for cryptocurrency-related legislation, planning to add regulated activities, including operating cryptocurrency exchanges and stablecoin issuance.

Despite ongoing regulatory progress, the Governor of the Bank of England has taken a more cautious stance. The Bank's Governor, Andrew Bailey, has repeatedly stated publicly that the widespread use of stablecoins could undermine public trust in the domestic currency and even pose systemic risks to the financial system.

Canada: Regulatory Ambiguity, Shaping Regulation

Policy Progress Speed: ★★

Compared to markets such as the US and the EU, Canada's policy is more conservative, and the local stablecoin market is developing slowly.

In December 2022, the FTX collapse triggered global crypto market turmoil, prompting the Canadian Securities Administration (CSA) to tighten policies, bringing stablecoins into the regulatory scope of "securities and/or derivatives."

Since 2023, the CSA has subsequently released two key documents, SN 21332 and SN 21333, outlining a regulatory framework for "fiat-pegged stablecoins." Under the relevant provisions, stablecoin issuers must register as securities issuers, submit a prospectus, or sign a commitment letter approved by the CSA.

Last month, the Canadian banking regulatory agency stated that it is prepared to regulate stablecoins, and the regulatory framework is under development.

Brazil: Strict Control Orientation

Policy Progress Speed: ★

According to data from the Central Bank of Brazil, over 90% of cryptocurrency transactions in the country involve stablecoins, mainly used for cross-border payments. However, this trend has also raised compliance concerns.

The President of the Central Bank of Brazil, Gabriel Galipolo, stated that the Central Bank initially believed the popularity of stablecoins was due to their convenient way for the public to hold US dollars. However, upon further investigation, it was found that a large volume of stablecoin transactions is related to cross-border shopping, and the transaction method is opaque, potentially being used for tax evasion or money laundering activities.

As a result, the Central Bank of Brazil proposed a new draft regulation in December 2024, aiming to include stablecoins in the foreign exchange regulatory system and prohibit transfers to wallets not controlled by Brazilian entities.

Overall, Brazil's regulatory direction is very clear: with strict control as a premise, the focus is on suppressing high-risk transaction scenarios.

Despite the tightening regulation, traditional banks are beginning to explore compliance paths. Brazil's largest bank, Itau Unibanco (with over 55 million customers), is planning to launch a stablecoin pegged to the real. Currently, Itau is studying the related experiences of other banks and awaiting the establishment of Brazil's stablecoin regulatory framework.

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