Date

June 16, 2025

Overview of Stablecoin Regulatory Situations Across Countries

This document summarizes the regulatory situations regarding stablecoins, which have been gaining prominence as cryptocurrencies in recent years, across major countries and regions.

Definition of Stablecoins

First, let’s review the definition of stablecoins.

Stablecoins are cryptocurrencies with the following characteristics that serve as a bridge between fiat currencies and cryptocurrencies. In global blockchain projects, it has become common practice to pay project contributors with USD-pegged stablecoins instead of their own issued tokens.

Issuance Method	Digital currency using blockchain and cryptographic technologies
Price	Designed to maintain a 1:1 peg with fiat currencies or commodities (such as gold). Therefore, prices tend to be more stable than other cryptocurrency tokens
Advantages	• Low transfer costs and fast transfer speeds (compared to fiat currency SWIFT transfers between banks) • Seamless exchange with other cryptocurrency tokens (though chain and protocol compatibility issues exist) • Widespread adoption as a means of exchange for digital assets like NFTs • Ability to incorporate payment execution into smart contracts
Challenges	Expansion of adoption as a payment method in the real world remains a challenge: • Payment method for businesses • Peer-to-peer transfer method • Integration with credit card payments, etc.While the ease of cross-border transfers is an advantage, anti-money laundering measures have become a concern

Currently issued stablecoins are mostly pegged to fiat currencies, with USD having an extremely high market share (estimated over 95% according to major market information sources).

Reference: https://writing.tanelabs.com/%e6%97%a5%e6%9c%ac%e8%aa%9e/2025%e7%b1%b3%e5%9b%bd%e8%a6%8f%e5%88%b6%e3%83%ac%e3%83%9d%e3%83%bc%e3%83%88-vol2

Legislative Status by Country

The following table shows the legislative status in Japan, Europe, and the United States.

Legal frameworks were implemented ahead of schedule in Japan and Europe between 2022-2023 and are already in effect. Meanwhile, in the United States under the Biden administration, unclear situations regarding securities classification continued for stablecoins, similar to other digital tokens.

With the change to the Trump administration this year, urgent legislation for stablecoin laws has been ordered by the President. This order issued around February aimed for new law enactment within approximately 100 days, but as of May 21, legislation has not been enacted and discussions continue in both the House and Senate.

Region	Legislation	Enactment Date	Effective Date
Japan	Amended Payment Services Act (R4 Amendment)	June 3, 2022	June 1, 2023
Europe	MiCA	April 20, 2023	June 30, 2024
Europe	Electronic Money Directive	September 16, 2009	October 2009
United States	GENIUS Act	Under Congressional review	N/A
United States	STABLE Act	Under Congressional review	N/A

※The table shows enactment and effective dates for stablecoin-related provisions, not the establishment dates of entirely new laws

※The Electronic Money Directive does not directly mention stablecoins, but MiCA classified stablecoin types into two frameworks (ART and EMD), making stablecoins classified as EMD subject to the Electronic Money Directive (detailed below)

Country Analysis: Japan

Japan has two types of stablecoin issuance methods. The newly established Electronic Payment Instrument Trading Business, created with stablecoins in mind, regulates the handling rather than issuance of these instruments (though money transfer service providers can also issue them).

	Electronic Payment Instrument Trading Business	Money Transfer Business
Definition	Services that transfer, circulate, and intermediate electronic payment instruments (with stablecoins in mind) issued by banks or money transfer service providers.	Applies to “exchange transactions” conducted by non-bank entities. Generally prepaid-type remittance services and services enabling payment transactions between two parties.Services that accept funds and provide remittance
Jurisdiction	Subject to the Payment Services Act	Subject to the Payment Services Act

Both are business types regulated under the Payment Services Act, but detailed regulations differ for each business type within the law. Money transfer business is subject to particularly strict regulations because it is a category for non-bank financial institutions to conduct exchange transactions (before this law’s enactment, they could only be regulated under the Banking Act).

	Electronic Payment Instrument Trading Business	Money Transfer Business
Licensing System	Registration system (generally simpler than authorization)	Registration system (generally simpler than authorization)
License Requirements	• Adequate business operation structure • Financial foundation • Implementation of user protection measures	• Must be a stock company• Financial foundation • Internal controls ※More stringent than Electronic Payment Instrument Trading Business due to bank-like operations
Business Scope	Payment and intermediation of third-party issued stablecoins	Issuance and remittance of stablecoins
Consumer Protection Regulations	• Segregation and protection obligations for customer assets • Prohibition of accepting money from customers • Important matter explanation obligations, complaint management system	• Segregation and deposit obligations for customer assets • Prior explanation obligations, refund obligations, complaint handling system ※More stringent asset protection measure requirements
Financial Requirements	Certain financial foundation	Performance guarantee deposit or guarantee contractObligation to maintain capital adequacy ratio regulations
Anti-Money Laundering Measures	Subject to JAFIC. Transaction verification including KYC, transaction record obligations, and suspicious transaction reporting obligations	Subject to JAFIC. Same obligations as left
Regulatory Authority	Financial Services Agency	Financial Services Agency
Penalties	Administrative guidance, business suspension orders, business improvement orders, fines, etc.	Administrative guidance, business suspension orders, business improvement orders, fines, etc.
Other Features	• Requires contractual agreement with issuers to clarify responsibility sharing for damage compensation regarding customer assets (Article 62-15)
Major Operators	SBI VC Trade (First registered operator)	PayPay (PayPay Money), Rakuten (Rakuten Cash), Kyash, etc.

Additionally, in Japan, when banks engage in stablecoin business (issuance or intermediation), they follow the Banking Act, and when issuing tokens using trust beneficiary rights schemes, they follow the Trust Act. (Trust beneficiary rights schemes are also subject to Electronic Payment Instrument Trading Business under the Payment Services Act)

While interest payments are not explicitly prohibited in regulations, issuance with securities characteristics would be treated as securities and subject to securities transaction laws.

Currently, no stablecoins specifically using money transfer business registration exist in Japan. (JPY-pegged JPYC uses blockchain technology but is designed as a prepaid payment instrument (third-party issued type), equivalent to prepaid electronic money. It has functional limitations such as inability to use for peer-to-peer transfers (final cash conversion of received funds).) JPYC has announced plans to provide stablecoins using money transfer business around summer.

However, many operators already registered for money transfer business exist, and these companies may enter the market as stablecoin adoption progresses. (Types 1-3 exist, with Type 1 or 2 operators able to issue stablecoins.) Money transfer operators can already issue stablecoins under the current system, and several operators possess powerful payment merchant networks, giving them competitive advantages in the new stablecoin payment market.

Reference: List of Registered Money Transfer Service Providers (R7.4.30) https://www.fsa.go.jp/menkyo/menkyoj/shikin_idou.pdf

Similarly, existing banks are also positioned to enter the stablecoin market relatively easily (at least systemically). Domestically, Kitaguni Bank has been issuing the regional currency “Tochika” as a deposit-type stablecoin since January 2024, while other banks like Aozora Bank and Mitsubishi UFJ Trust and Banking have announced exploratory initiatives.

For banks, the key point will be how to leverage stablecoin advantages in combination with bank-specific services such as “deposit acceptance (and interest payments),” “exchange transactions,” and “lending,” to develop business.

Country Analysis: Europe

Europe first classifies stablecoins into the following two types:

	ART	EMD
Definition	Tokens whose value is linked to multiple assets (e.g., commodities, currencies, etc.).	Tokens whose value is linked to a single fiat currency and designed for payment purposes.
Jurisdiction	Subject to MiCA regulations	Subject to Electronic Money Directive regulations (same treatment as other electronic money)

As shown above, different regulatory systems apply, resulting in different regulatory content. Additionally, the Electronic Money Directive is an EU directive and not specific legislation itself, so concrete regulations are legislated in each country based on the directive (resulting in detailed rule differences between countries).

	ART	EMD
Licensing System	Authorization system (some regulatory relief for small-scale issuers)	Authorization system
License Requirements	• EU entity establishment • White paper publication • Management competency requirements, internal controls • Submission of business contracts and capital information	• EU entity establishment • Management competency requirements, internal controls • Meeting capital requirements
Business Scope	Both issuer regulations and service provider (CASP) regulations	Primarily issuer regulations
Consumer Protection Regulations	• Good faith obligation • Information disclosure obligations through white papers, etc. • Clarification of redemption rights• Prohibition of interest payments (to prevent investment product classification)	• Redemption obligations • Customer asset segregation obligations • Information disclosure obligations
Financial Requirements	• 1:1 backing reserves • Minimum capital amount setting by issuance scale • Regular asset information disclosure and audit obligations	• Minimum capital amount designation • Additional capital regulations based on issued money balance and transaction volume
Anti-Money Laundering Measures	• Implementation of strict anti-money laundering regulations • KYC and CDD (Customer Due Diligence) obligations • Collection and storage obligations for sender/recipient information for all transactions (from December 30, 2024) ※Same level of regulation as other cryptocurrency providers and financial institutions	• KYC, transaction monitoring, suspicious transaction reporting obligations • Relatively minor compared to MiCA
Regulatory Authority	Primarily EBA (European Banking Authority) and national financial authorities	EU national financial authorities
Penalties	Administrative sanctions, fines, and other sanctionsSuspension of intra-regional business continuation for serious violations	Administrative sanctions, fines, and other sanctions

USDC and others are specifically registered as EMD stablecoins. However, USDT, which currently holds an overwhelming position among stablecoins, has not applied and faces a somewhat unstable circulation environment within the EU. (This has led to impacts such as Binance suspending USDT handling.)

A characteristic of EU regulations is the mandatory establishment of entities within the region, requiring existing stablecoin issuers to establish entities somewhere within the EU to legally circulate within the EU.

Additionally, anti-money laundering customer checks and tracking obligations appear relatively strict compared to Japan.

Furthermore, CARF (Crypto-Asset Reporting Framework), an international tax avoidance framework by the OECD, has begun operation as an international treaty, with EU member countries at its center. (Japan has also joined this treaty and is expected to implement similar initiatives from January 1, 2026, through domestic law amendments.) CARF enables participating countries to exchange transaction histories of cryptocurrency transactions by non-residents through domestic operators (conversely, operators in participating countries are obligated through domestic law to collect and store basic information and transaction histories of non-residents and provide information to other participating countries through their national authorities).

Reference: List of countries agreeing to CARF implementation (as of May 2025) Armenia, Australia, Austria, Barbados, Belgium, Belize, Brazil, Bulgaria, Canada, Chile, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Japan, South Korea, Liechtenstein, Lithuania, Luxembourg, Malta, Mexico, Netherlands, Norway, Portugal, Romania, Singapore, Slovakia, Slovenia, South Africa, Spain, Sweden, Switzerland, United Kingdom, United States *British territories agreeing to CARF implementation by 2027: Guernsey, Jersey, Isle of Man, Cayman Islands, Gibraltar The United States once agreed to join but has taken an unclear stance regarding specific implementation timing.

Country Analysis: United States (Under Review)

The United States, the issuing country of the dollar which boasts high stablecoin market share, lags behind Japan and Europe in legal framework development, with full-scale legislative work beginning after the Trump administration took office in February 2025.

The direction of stablecoin legislation in the United States is roughly as follows:

Authorized stablecoins will be treated as payment instruments and excluded from securities law regulations
Similar to Japan and Europe, adopts a licensing authorization system under federal jurisdiction (with room for state law selection for small-scale operators)

Currently, two types of stablecoin bills proposed by the House and Senate respectively are under congressional review, with daily revisions. Below is a comparison of these two bills (information as of June 4, 2025):

	GENIUS Act	STABLE Act
Stablecoin Definition	Digital assets for which the issuer represents redemption, conversion, or buyback at a fixed monetary value. (Excluding currency and traditional financial products)	Digital assets used or designed as payment or settlement instruments.Issued in currency denomination with issuer obligations to redeem, convert, or buy back at fixed monetary value.
Licensing System	Federal authorization system(Issuance below $100 billion may choose state-level regulation)	Federal authorization system.State-level regulation can be chosen but with activity restrictions within jurisdiction
License Requirements	• Reserve regulations • Monthly reporting obligations • Audit obligations • AML annual certification obligations • Prohibition of interest payments	• Reserve regulations • Monthly reporting obligations • Audit obligations • Capital liquidity requirements • Prohibition of interest payments
Business Scope	Primarily regulates issuers and custodial operators while also applying some regulations to distribution operators in relation to handling restrictions	Primarily regulates issuers while incorporating regulations for handling operators and custodial operators
Consumer Protection Regulations	• Prohibition of false advertising suggesting government backing or guarantees • Fee disclosure obligations • Priority claims in bankruptcyCustody Operators • Reserve handling restrictions (must treat as belonging to coin holders) • Segregation obligationsSales Operators • Prohibition of handling unauthorized stablecoins • Foreign-issued stablecoins require equivalent domestic management standards and government supervision	• Prohibition of false advertising suggesting government backing or guarantees, plus obligation to actively display that there is no government guarantee • Priority claims in bankruptcyCustody Operators • Government disclosure obligations regarding customer asset protection systems • Segregation obligationsSales Operators • Prohibition of handling unauthorized stablecoins • US authorities review foreign-issued stablecoins and publish lists
Financial Requirements	• Specific designation of eligible claims as reserves • Capital requirements, liquidity standards • Monthly inspections	• Specific designation of eligible claims as reserves • Prohibition of reserve collateralization, re-collateralization, and reuse • Capital requirements, liquidity standards • Monthly inspections
Anti-Money Laundering Measures	• Compliance with Bank Security and sanctions laws (financial institution level) • CDD implementation • Annual certification	• Compliance with Bank Security and sanctions laws (financial institution level) • CDD implementation
Regulatory Authority	Federal banking regulatory authorities, inter-agency coordination, Treasury Secretary, etc.	Detailed supervisory authorities differ by entity, but federal level is similar. However, enforcement is state authority jurisdiction
Penalties	• Fines, imprisonment • Authorization revocation, suspension orders, cease ordersSales Operators • When issuers conduct AML measures, can issue handling prohibition orders to distribution providers	• Various fines • Registration revocation, suspension orders, cease orders
Other	Grace period for unlicensed operators is 2 years from enforcement	Grace period for unlicensed operators is 18 months from enforcement

※Unless otherwise specified, all obligations apply to issuers

The GENIUS and STABLE bills have officially undergone 1-2 draft revisions, and both bill contents appear to be gradually converging. While details differ, the overall framework seems to be moving toward stablecoin business regulation under national authority management similar to Japan and Europe.

Additionally, since many operators already issuing and circulating stablecoins exist in the United States, grace periods for unlicensed operators are included as a feature.

After law enforcement, movements are expected during this grace period for domestic issuers and custodial operators to obtain permits and build systems, trading platforms and other sales operators to review handled stablecoins, and foreign issuers to decide on registration responses with domestic regulatory authorities. (Future attention will focus on which country’s system-based registration or authorization the US government will recognize as permitted foreign stablecoins.)

Conclusion

Having introduced stablecoin bills from major regions (Japan, Europe, and the US), common points include the following:

Stablecoins are digital assets pegged 1:1 to some asset (mostly currencies) and positioned as payment instruments
Government authorization or registration systems
Regulations centered on issuers
Customer asset protection regulations equivalent to other operators handling financial products
Regulation of yield provision
Emphasis on anti-money laundering measures