US GENIUS Act Sets Global Benchmark: EU, UK, Asia Seek Similar Stablecoin Standards

• The U.S. GENIUS Act aims to establish a clear, federally backed framework specifically for single fiat-backed stablecoin issuers.
• Other major jurisdictions are developing or refining their own stablecoin regulations.
• While the U.S. law views stablecoins as integral to the future payments ecosystem, some countries, such as Japan, still consider stablecoins experimental.

With the recent passage of the U.S. GENIUS Act (Guiding and Establishing National Innovation for U.S. Stablecoins), America has established a regulatory benchmark in the evolving stablecoin landscape.

Designed to create an enforceable framework for single fiat-backed stablecoin issuers, the GENIUS Act aims to balance innovation with consumer and systemic protection.

Now, major jurisdictions worldwide are drafting or refining their own regulations, with many seeking to implement rules similar to those in Washington.

Here’s a look at which countries are advancing stablecoin regulations and how their approaches differ.

European Union

Unlike the GENIUS Act, which focuses on one category of digital asset, the EU’s MiCA (Markets in Crypto-Assets) regulation aims to govern all crypto-assets not already covered by existing EU financial services law.

While this includes stablecoins, MiCA also addresses utility tokens, asset-referenced tokens, and the activities of crypto service providers such as exchanges.

MiCA requires stablecoin issuers to be established within the EU and authorized by an EU supervisory authority.

In contrast, the GENIUS Act permits foreign issuers to operate in the U.S., provided they register with the appropriate regulatory agencies.

While MiCA takes a more protectionist stance, GENIUS arguably offers a clearer path for international compliance.

United Kingdom

In April, the U.K. Treasury unveiled draft rules for the crypto sector, including specific provisions for stablecoins.

The Treasury’s proposed crypto regime states that “qualifying stablecoins” in the U.K. will require authorization from the Financial Conduct Authority (FCA).

The FCA will have the authority to impose client asset rules on fiat reserves, treating them similarly to client money under existing financial regulations.

In stark contrast, the U.S. GENIUS Act delegates oversight to state authorities for stablecoin issuers with circulation under $10 billion.

Like other countries, the U.K. requires a physical or legal presence in the country, limiting access for foreign issuers.

Japan

Japan is also taking careful steps toward regulating stablecoins, with a recent proposed revision to the Payment Services Act signaling a nuanced, tailored approach.

The Japanese bill , submitted to the National Diet by the Financial Services Agency in March, builds on an existing framework that allows stablecoins to be issued by three categories of regulated financial institutions: banks, trust companies, and money transfer businesses.

This contrasts with the GENIUS Act, which for the first time in U.S. law creates a federal framework specifically designed for single fiat-backed stablecoin issuers.

One of the most notable proposed changes in Japan involves greater flexibility in stablecoin reserve management.

Previously, trust-style stablecoins issued via trust banks on behalf of third parties were required to hold 100% of reserves in demand deposits at licensed banks.

The new bill would allow up to half of those reserves to be allocated into government bonds or term deposits.

This aligns with the spirit of the GENIUS Act, which also mandates fully backed reserves held in secure, liquid assets.

However, the U.S. law allows regulatory discretion regarding asset types and custody standards.

Japan’s regulatory regime also regards stablecoins as highly experimental.

Just this year, SBI VC Trade became the first company to receive a license to deal in foreign stablecoins such as USDC.

In the U.S., the GENIUS Act assumes a future in which stablecoins are not just experimental but integral to the broader payments ecosystem, with explicit provisions for their use in commerce and the traditional banking system.

Hong Kong

In 2025, Hong Kong made a significant leap forward in stablecoin regulation by passing its Stablecoins Ordinance Regime, set to be fully enforced in 2026.

While developed independently, this new framework closely resembles the U.S. GENIUS Act, positioning Hong Kong as one of Asia’s first jurisdictions to implement a licensing system aligned with the American model.

Like the GENIUS Act, Hong Kong’s regime mandates that all stablecoin issuers obtain regulatory licenses before operating.

This licensing requirement is central to both frameworks, underscoring the regulators’ shared view that stablecoins warrant dedicated oversight to protect financial stability and consumer interests.

However, Hong Kong places greater emphasis on investor and consumer protection than the GENIUS Act.

Under Hong Kong’s bill, only stablecoins issued by HKMA-licensed issuers may be offered to retail investors.

In contrast, while the GENIUS Act requires stablecoin issuers to be licensed and adhere to strict requirements, it allows for a broader range of stablecoin offerings to enter the U.S. market.