Rules for stablecoins and tokenised assets have moved apart across the major jurisdictions over the past year, raising the prospect that cross-border activity stalls, a concern echoed by industry experts. As noted by a 2024 Financial Stability Institute paper, the regulatory picture has long been diverse and fragmented.
In the United States, the GENIUS Act sets a federal definition of payment stablecoins and establishes who may issue them and how they must operate, requiring full one-to-one backing in high-quality liquid assets alongside monthly public reporting on reserves that an independent accounting firm must examine.
In the United Kingdom, the Financial Conduct Authority (FCA) finalized its crypto asset framework in mid-2026, lowering capital requirements for stablecoin issuers to strike a balance between managing risk and supporting innovation.
In the European Union, the European Commission has been asked to clarify how tokenised assets are treated and to provide greater legal certainty for stablecoin arrangements that involve more than one issuer, a step eurozone finance ministers have supported.
The gaps between these regimes reach into reserve requirements, capital treatment and legal protections. Industry figures say they will make it harder to build projects that operate across borders.
