Key takeaways
- The EU's MiCA has applied to stablecoin issuers since 30 June 2024. Hong Kong's licensing regime started on 1 August 2025, the US GENIUS Act takes effect on 18 January 2027, and the UK's regime is scheduled for October 2027.
- Most regimes regulate issuers and the platforms that offer stablecoins, not companies that hold or receive them. They reach you through what your providers may offer.
- The same token can have a different status in each place: USDC is authorized under MiCA, while USDT isn't, and in the UAE only licensed dirham tokens may be used to pay for goods and services onshore.
- Check which rules your providers operate under in each country where you hold or move stablecoins, and keep records of where your tokens came from.
The short answer
Stablecoin rules are now law in most large financial centers, but they arrive at different times and treat the same token differently. In every jurisdiction in this guide, the rules regulate issuers and the platforms that offer stablecoins. A company that holds or receives USDC or USDT for its own business isn't the target. It feels the rules through its providers: which tokens they may offer, and what they must ask.
At a glance
| Main rules | In force | What it means for a business holding stablecoins | |
|---|---|---|---|
| European Union | MiCA | E-money tokens since 30 June 2024; service providers since 30 December 2024 | Authorized tokens such as USDC and EURC; providers expected to wind down services in non-compliant tokens like USDT |
| United States | GENIUS Act and OCC rule | 18 January 2027 | From 18 July 2028, US platforms may only offer stablecoins from permitted or qualifying foreign issuers |
| United Kingdom | FCA regime for qualifying stablecoins; Bank of England for systemic ones | Scheduled for October 2027 | Issuers and custodians need FCA authorization |
| United Arab Emirates | CBUAE Payment Token Services Regulation | 2024 | Onshore payments for goods and services in licensed dirham tokens only |
| Hong Kong | Stablecoins Ordinance | 1 August 2025; first licences 10 April 2026 | Licensed issuers, starting with HSBC and Anchorpoint Financial |
| Singapore | MAS single-currency stablecoin framework | Framework published 2023; legislation consulted on in September 2026 | "MAS-regulated stablecoin" label for issuers that meet it |
European Union: MiCA
MiCA's rules for e-money tokens, stablecoins referencing one official currency, have applied since 30 June 2024, and its rules for crypto-asset service providers since 30 December 2024. An e-money token must be issued by an authorized credit institution or e-money institution, which must keep at least 30% of the funds it receives in bank deposits, more for significant tokens. Issuers and service providers can't pay interest on them.
Circle's French entity issues USDC and EURC under MiCA, and on 14 October 2026 the European Banking Authority classified USDC as the first significant e-money token, out of 45 notified. Tether hasn't applied for USDT. On 8 October 2026, ESMA said authorized providers should stop services related to non-compliant stablecoins for EU clients, keeping only winding-down services for a limited time. See is USDT MiCA compliant? and EURC vs USDC.
United States: the GENIUS Act
The GENIUS Act became law on 18 July 2025 and takes effect on 18 January 2027. It sets who may issue payment stablecoins in the US, the reserves that must back them, and which stablecoins US platforms may offer: from 18 July 2028, only those of permitted issuers or qualifying foreign issuers. The OCC issued the first final rule under the Act on 21 October 2026; other regulators' rules are still outstanding. Issuers can't pay holders interest or yield. See the GENIUS Act for non-US businesses.
United Kingdom
The UK splits stablecoins in two. The FCA authorizes and supervises issuers and custodians of qualifying stablecoins, and published its policy on stablecoin issuance on 30 June 2026. Stablecoins that HM Treasury recognizes as systemic will be supervised jointly by the Bank of England and the FCA. The Bank's policy statement of 22 June 2026 dropped proposed holding limits for individuals and businesses, replaced them with a temporary issuance cap of £40 billion per systemic stablecoin, and set reserves at 70% short-term UK government debt and 30% unremunerated deposits at the Bank. The FCA's wider crypto regime is scheduled to start in October 2027.
United Arab Emirates
The Central Bank of the UAE's Payment Token Services Regulation, issued in 2024, covers payment tokens onshore. Only licensed dirham payment tokens may be used to pay for goods and services in the UAE. Foreign payment tokens, such as dollar stablecoins issued abroad, must be registered, and can then be used only to buy virtual assets. The first registered foreign token, Universal Digital's USDU, was registered on 29 January 2026, and RAKBANK received in-principle approval for a dirham stablecoin on 7 January 2026.
The financial free zones have their own regimes: on 17 February 2025, the Dubai Financial Services Authority recognized USDC and EURC as the first stablecoins approved under the DIFC's crypto token regime. For paying UAE suppliers in dirhams by bank transfer, see the AED account.
Hong Kong
Hong Kong's Stablecoins Ordinance took effect on 1 August 2025, requiring a licence from the Hong Kong Monetary Authority to issue fiat-referenced stablecoins in Hong Kong, or to issue Hong Kong dollar stablecoins anywhere. The HKMA assessed 36 applicants and granted the first licences on 10 April 2026, to The Hongkong and Shanghai Banking Corporation and Anchorpoint Financial, a venture involving Standard Chartered.
Singapore
The Monetary Authority of Singapore published its framework for single-currency stablecoins pegged to the Singapore dollar or a G10 currency and issued in Singapore in 2023. Only issuers that meet it may use the label "MAS-regulated stablecoin". On 1 September 2026, MAS consulted on amending the Payment Services Act 2019 to put the framework into law, including a licensing regime and powers to designate systemic stablecoins; the consultation closed on 16 October 2026.
What to do
- Know where your providers are regulated, and under which regime they offer you each token.
- Match tokens to counterparties. A token that's fine for a supplier in one country may not be one their bank or provider can accept.
- Keep records of where tokens came from, which every regime's providers can ask for. See also the Travel Rule and DAC8 and CARF.
- Watch the dates: 18 January 2027 in the US, and the UK regime in October 2027.
How this works with Align
Align supports USDC, USDT and EURC, and pays out in USD, EUR, GBP and AED from named accounts. Align Payments Ltd. is registered with FINTRAC in Canada as a money services business. It isn't authorized under MiCA, doesn't onboard companies based in the UAE, and doesn't issue stablecoins. This guide is general information, not legal advice.
Sources
- Regulation (EU) 2023/1114, Markets in Crypto-Assets (MiCA)
- European Banking Authority, USDC classified as the first significant e-money token in the EU (14 October 2026)
- ESMA, Opinion on crypto-asset services for non-MiCA-compliant ARTs and EMTs (8 October 2026)
- OCC, Final rule to implement the GENIUS Act (21 October 2026)
- Bank of England, Sterling-denominated systemic stablecoins: policy statement (June 2026); Latham & Watkins, UK cryptoasset regulatory tracker (accessed November 2026)
- Unlock Blockchain, UAE Central Bank payment token regulation; The National, RAKBank receives initial approval to launch dirham-backed stablecoin (January 2026)
- Bitcoin.com News, Universal launches UAE central bank-registered USD stablecoin (January 2026)
- Circle, USDC and EURC become first stablecoins recognized by Dubai International Financial Centre (February 2025)
- Hong Kong Monetary Authority, Granting of stablecoin issuer licences (10 April 2026)
- Monetary Authority of Singapore, MAS consults on legislative amendments to implement stablecoin regulatory framework (September 2026)
Common questions
- Which country has the most developed stablecoin rules?
- The EU's MiCA has been in force longest for stablecoins, applying to e-money token issuers since 30 June 2024, and has authorized issuers, including Circle for USDC and EURC. Hong Kong licensed its first issuers in April 2026. The US and UK regimes are written but not yet in force.
- Is it legal for my company to hold USDT?
- In the jurisdictions in this guide, the rules regulate issuers and service providers, not companies holding stablecoins for their own business. What changes is what providers may offer you: in the EU, ESMA's October 2026 opinion expects authorized providers to stop most services in tokens like USDT that aren't MiCA compliant. Check local rules with an adviser.
- Can I pay a UAE supplier in USDC?
- The Central Bank of the UAE's Payment Token Services Regulation reserves payments for goods and services onshore to licensed dirham payment tokens, and lets registered foreign payment tokens be used only to buy virtual assets. Rules differ in the financial free zones: the DIFC recognized USDC and EURC in February 2025. Paying a UAE supplier in dirhams by bank transfer avoids the question.
- Do these rules affect the Travel Rule or tax reporting?
- Those are separate regimes that apply alongside them: the Travel Rule covers the information that travels with a transfer, and DAC8 and CARF cover reporting to tax authorities.
This guide is general information, not legal, tax or financial advice. Rules and providers' terms change; check the sources linked above and take advice on your own situation.