How to Obtain a Stablecoin License: The 2025 Global Guide for Infrastructure Builders

How to Obtain a Stablecoin License: The 2025 Global Guide for Infrastructure Builders

For stablecoin infrastructure firms building cross-border rails, the licensing landscape is no longer optional background. It defines who can operate globally. Whether you're issuing stablecoins, providing custody, or embedding on/off-ramps into infrastructure, this guide breaks down what every serious operator must understand to go live compliantly across major markets in 2025.

The stablecoin market exceeded $170 billion in market capitalization in 2024, with transaction volumes surpassing Visa and Mastercard combined. Yet regulatory clarity only arrived in 2025 with the passage of landmark legislation: the US GENIUS Act, Hong Kong's Stablecoins Ordinance, the EU's MiCA regulation, and evolving frameworks in Singapore and the UK. For platforms like Bridge and ambitious infrastructure builders seeking global scale, understanding these licensing requirements has become a strategic imperative, not a compliance afterthought.

This comprehensive guide provides actionable intelligence on obtaining stablecoin licenses across every major jurisdiction, with practical timelines, cost expectations, and strategic considerations for multi-jurisdictional operations.

Quick Reference: Global Stablecoin Licensing Overview 2025

Jurisdiction	Primary Regulator	Key Legislation	Status	Timeline	Min. Capital	Reserve Requirement
United States	OCC, Federal Reserve, FDIC	GENIUS Act	Live (July 2025)	120 days	Varies by pathway	1:1 backing, liquid assets only
Hong Kong	HKMA	Stablecoins Ordinance	Live (Aug 2025)	3-6 months	HK$25M (~$3.2M USD)	100% backing + overcollateralization
Singapore	MAS	Payment Services Act (SCS Framework)	In development	TBA (2025-26)	S$1M or 50% opex	100% backing, 5-day redemption
European Union	National NCAs, EBA	MiCA Regulation	Fully applicable (Dec 2024)	3-6 months	Varies by member state	100% reserves, EU-based for EMTs
United Kingdom	FCA, Bank of England	Proposed Framework (CP25/14)	Draft (final 2026)	TBA (2026-27)	TBA	100% backing, 5% liquid minimum
Switzerland	FINMA	Banking/Securities Acts	Case-by-case	6-12 months	CHF dependent	Varies by structure
UAE (Dubai)	VARA	Virtual Assets Framework	Live	4-8 months	Varies	Case-by-case
Japan	FSA	Payment Services Act	Live	6-9 months	JPY dependent	1:1 backing

Top Jurisdictions for Stablecoin Issuers in 2025

Based on regulatory clarity, market access, and operational feasibility, the top jurisdictions for stablecoin licensing in 2025 are:

1. United States (GENIUS Act): Largest market, clear federal framework, 120-day approval timeline, access to institutional capital.

2. Hong Kong: Asia's gateway, strong regulatory framework, 36 applications received in first batch, early 2026 licenses expected.

3. European Union (MiCA): Single license for 27 countries, passporting rights, established compliance standards, institutional credibility.

4. Singapore: Regional hub, sophisticated financial ecosystem, progressive regulatory approach, strong rule of law.

5. United Kingdom: Major financial center, comprehensive framework in development, access to European and global markets.

United States: How to Get a Stablecoin License Under the GENIUS Act

What is the GENIUS Act?

The Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act, signed July 18, 2025) is the United States' first comprehensive federal stablecoin regulation. It establishes clear definitions, regulatory pathways, and consumer protections while creating the world's largest compliant stablecoin market.

Who Can Apply for a US Stablecoin License?

The GENIUS Act creates three distinct licensing pathways:

Federal Qualified Nonbank Issuers: Nonbank financial entities approved by the Stablecoin Certification Review Committee (Treasury Secretary, Federal Reserve Chair, FDIC Chair). Supervised by the Office of the Comptroller of the Currency (OCC). This pathway is optimal for fintech firms and crypto-native companies seeking federal oversight without a banking charter.

Bank/Credit Union Subsidiaries: Traditional financial institutions issuing stablecoins through subsidiaries. Subject to existing primary federal banking regulator. Best for established banks expanding into digital assets.

State Qualified Issuers: Entities under $10 billion in outstanding stablecoins may choose state-level regulation if the state regime is "substantially similar" to federal standards. Reduces regulatory burden for emerging issuers but requires federal transition above $10 billion threshold.

US Stablecoin License Requirements

Reserve Requirements: 1:1 backing with permitted assets only (US coins/currency, insured bank deposits, short-dated Treasury bills, repos backed by Treasuries, government money market funds, central bank reserves). No interest payments to holders permitted.

Compliance Obligations: Certified AML/CFT programs, periodic reports examined by registered accounting firms, technical capability to freeze/seize tokens per lawful orders, audited annual financials for issuers over $50 billion.

Application Timeline: 120 days maximum. Applications not acted upon are deemed approved. Regulators must justify denials and permit appeals.

How to Apply for a US Stablecoin License: Step-by-Step

1. Determine Pathway: Select federal nonbank, bank subsidiary, or state issuer based on business model and scale.

2. Prepare Documentation: Business plans, reserve custody agreements, AML/CFT programs, risk management frameworks, technical compliance systems.

3. Engage Pre-Application: Schedule meetings with relevant regulator (OCC for nonbanks) to discuss model and expectations.

4. Submit Complete Application: Include all required documentation demonstrating baseline requirement compliance.

5. Respond to Regulator Queries: Provide complete, timely responses to information requests.

6. Receive Approval: Within 120 days or deemed approved.

Cost Expectations: Application fees $50,000-$100,000+, legal/advisory $200,000-$1,000,000, annual compliance $500,000-$2,000,000+.

Foreign Stablecoin Issuers Accessing the US Market

Non-US issuers face restrictions but can access US markets if from jurisdictions with comparable regulatory frameworks (determined by Treasury Secretary). Requirements include OCC registration, US-based reserves sufficient for US customer liquidity, and demonstrated compliance with US lawful orders.

For detailed US stablecoin licensing support, contact Buckingham Capital Consulting: 020 7866 2512 | info@buckinghamcapitalconsulting.co.uk

Hong Kong: Obtaining an HKMA Stablecoin License

Hong Kong Stablecoins Ordinance Overview

Hong Kong's regulatory framework (live August 1, 2025) covers fiat-referenced stablecoins (FRS) under Hong Kong Monetary Authority supervision. The HKMA received 36 applications by September 30, 2025, with first licenses expected early 2026.

Who Needs a Hong Kong Stablecoin License?

Mandatory licensing: FRS issuers in Hong Kong, HKD-linked FRS issuers (anywhere globally), entities actively marketing FRS to Hong Kong public.

Hong Kong Stablecoin License Requirements Checklist

Corporate Structure: Hong Kong incorporated company OR authorized institution under Banking Ordinance.

Financial Requirements: HK$25 million minimum paid-up capital (~$3.2 million USD), HK$3 million liquid capital, 12+ months operating expenses in liquid assets.

Reserve Standards: 100% backing minimum, overcollateralization expected, complete segregation from operational funds, protection against creditor claims.

Operational Requirements: Dedicated resources for licensed activities, HKMA consent for other business activities, senior management based in Hong Kong, no interest payments to holders.

Risk Management: Comprehensive frameworks covering credit, liquidity, market, technology, and operational risks. AML/CFT compliance programs meeting HKMA standards.

Hong Kong Stablecoin License Application Timeline

August 31, 2025: Early engagement deadline with HKMA

September 30, 2025: Target submission for first batch consideration

Early 2026: First licenses expected

Processing time: 3-6 months typical

Pre-existing issuers (operating before August 1, 2025) must apply by October 31, 2025 for provisional licenses.

Hong Kong Application Process

1. Early HKMA Engagement: Contact stablecoin_licensing@hkma.gov.hk for pre-application guidance.

2. Prepare Comprehensive Documentation: Business plans, independent compliance assessments, governance structures, reserve arrangements, IT systems specifications.

3. Submit Formal Application: Complete application package with all supporting materials.

4. HKMA Review Process: Regulator evaluation of financial soundness, operational capability, and compliance readiness.

5. License Grant: Inclusion in HKMA public register of licensed issuers.

Cost Expectations: Application/professional fees $300,000-$800,000, annual compliance $400,000-$1,500,000.

Singapore: MAS Stablecoin Framework and Licensing

Singapore MAS Framework Status

The Monetary Authority of Singapore (MAS) announced its stablecoin framework in August 2023 for single-currency stablecoins (SCS) pegged to SGD or G10 currencies. Legislative amendments to formalize the framework are in progress, with public consultation expected in 2025.

MAS-Regulated Stablecoin Label

Only issuers meeting all framework requirements can use the "MAS-regulated stablecoin" designation. This label distinguishes compliant stablecoins from unregulated tokens. Misrepresentation faces financial penalties or imprisonment.

Singapore Stablecoin License Requirements

Scope: Single-currency stablecoins pegged to SGD or G10 currencies (USD, EUR, JPY, GBP, etc.), issued exclusively from Singapore.

Reserve Requirements: 100% backing with high-quality liquid assets, monthly independent attestations, annual audits, segregated custody with approved custodians.

Capital Requirements: S$1 million minimum base capital OR 50% of annual operating expenses (whichever higher).

Redemption Rights: Par value redemption within 5 business days maximum.

Additional Requirements: White paper disclosure, Singapore-only issuance initially, AML/CFT and technology risk management compliance.

Singapore Licensing Thresholds

Over S$5 million circulation: Major Payment Institution (MPI) license required for "Stablecoin Issuance Service." Full framework applies, can use "MAS-regulated stablecoin" label.

Under S$5 million: Exempt from framework but cannot use regulated label. May apply voluntarily if planning growth beyond threshold.

Banks: Exempt from PSA licensing requirement but must meet framework standards.

Singapore Application Process (When Framework Goes Live)

1. MPI License Application: Apply under Payment Services Act for Stablecoin Issuance Service.

2. Framework Compliance Demonstration: Evidence of reserve management, capital adequacy, redemption procedures, risk management.

3. White Paper Submission: Comprehensive disclosure document.

4. MAS Review and Authorization: Evaluation and approval process.

5. Recognition as MAS-Regulated Stablecoin: Official designation upon compliance.

Timeline: Framework finalization expected 2025, with licensing available thereafter. Typical payment institution license processing: 4-8 months.

Cost Expectations: Application fees S$1,000-$5,000, professional services $250,000-$700,000, annual compliance $300,000-$1,000,000+.

European Union: Stablecoin Licensing Under MiCA Regulation

MiCA Regulation Overview

Markets in Crypto-Assets (MiCA) regulation is the world's first comprehensive EU-wide crypto-asset framework. Stablecoin provisions (ARTs and EMTs) became applicable June 30, 2024. Full implementation occurred December 30, 2024.

MiCA Stablecoin Categories

Asset-Referenced Tokens (ARTs): Stablecoins maintaining value by referencing multiple assets (currencies, commodities, crypto-assets). Must be EU-based and authorized.

E-Money Tokens (EMTs): Stablecoins pegged to single fiat currency. Must be issued by credit institutions or e-money institutions. EMT reserves must remain in EU.

Both categories may be designated "significant" by the European Banking Authority, triggering enhanced oversight.

EU Stablecoin License Requirements

Own Funds: Bespoke capital requirements based on stablecoin type and issuance volume. Higher standards for significant stablecoins.

Governance: Robust organizational structures, qualified management, internal controls, risk management systems, conflict of interest policies.

Reserve Management: Sufficient reserves covering all issued tokens, high-quality liquid assets, strict custody rules, regular audits.

Disclosure: Comprehensive white papers approved by National Competent Authority (NCA), transparency reports, material change notifications.

Compliance Programs: AML/CFT measures, market abuse prevention, complaints handling, orderly wind-down planning.

How to Apply for MiCA Stablecoin License: Step-by-Step

1. Select Home Member State: Choose EU country for primary authorization based on regulatory approach, processing efficiency, strategic location.

2. Prepare Application Package: White paper, business plan, governance documentation, reserve arrangements, compliance programs, financial projections.

3. Submit to National Competent Authority: Complete application to chosen NCA.

4. NCA Review Process: Evaluation of compliance with MiCA requirements (typically 3-6 months).

5. Authorization Grant: Upon approval, passporting rights across all 27 EU member states.

6. Ongoing Compliance: Regular reporting, audits, transparency disclosures, adherence to transaction limitations.

Passporting Advantage: Single authorization provides access to entire EU market. Notify home NCA to operate in additional member states.

MiCA Compliance and Enforcement

Penalties: Up to €15 million OR 3% of annual turnover (whichever higher). Personal liability for executives. Potential bans from crypto industry.

Significant Stablecoin Oversight: EBA direct supervision, stricter requirements, potential circulation limits, ECB veto power.

Service Provider Restrictions: Crypto exchanges must delist non-MiCA compliant stablecoins by Q1 2025 end.

Cost Expectations: Application fees €10,000-€50,000 (varies by member state), professional services €300,000-€1,000,000+, annual compliance €500,000-€2,000,000+.

United Kingdom: Preparing for UK Stablecoin Licensing

UK Framework Status

The Financial Conduct Authority (FCA) published Consultation Paper CP25/14 in May 2025, proposing comprehensive stablecoin regulation. Consultation closed July 31, 2025. Final rules expected 2026, with implementation following parliamentary approval in late 2026 or 2027.

Proposed UK Stablecoin License Requirements

Reserve Backing: 100% high-quality liquid assets, minimum 5% in on-demand bank deposits, dynamic Backing Asset Composition Ratio calculated every 14 days.

Statutory Trust Structure: Backing assets held on trust for coin holders, segregated accounts with independent custodians, issuer as trustee with fiduciary duties.

Redemption Rights: T+1 settlement (next business day), no minimum redemption amounts, clear procedures.

Interest Prohibition: Interest retained by issuer, not distributed to holders. Daily reconciliation of backing assets.

Risk Management: Comprehensive frameworks for liquidity, custody diversification, operational resilience, documented and board-overseen.

UK Application Timeline (Projected)

2026: Final rules publication

Late 2026 or 2027: Regime goes live post-parliamentary approval

FCA Authorization Required: Application to Financial Conduct Authority for issuing qualifying stablecoins

Systemic Stablecoin Framework: Bank of England consultation expected on widely-used stablecoins, potential access to BoE accounts, ongoing debate on ownership caps (£10,000-£20,000 individual, £10 million business).

UK Application Preparation

While the framework is not yet live, firms can prepare by:

1. Monitoring FCA Updates: Track final rules publication and implementation timeline.

2. Building Compliance Infrastructure: Design frameworks meeting proposed requirements.

3. Establishing Reserve Arrangements: Secure relationships with qualified UK custodians.

4. Developing Governance: Implement structures meeting FCA expectations.

5. Engaging Early: Contact FCA when application window opens.

Cost Expectations (Estimated): Application/professional fees £300,000-£900,000, annual compliance £400,000-£1,500,000+.

For UK stablecoin licensing preparation and strategy, contact Buckingham Capital Consulting: 020 7866 2512 | info@buckinghamcapitalconsulting.co.uk

Other Key Jurisdictions for Stablecoin Licensing

Switzerland

Regulator: FINMA (Swiss Financial Market Supervisory Authority)

Framework: Stablecoins regulated under adapted banking/securities regulations

Key Points: Payment tokens subject to AML laws, banking license may be required, clear regulatory guidance, crypto-friendly jurisdiction

United Arab Emirates (Dubai and Abu Dhabi)

Dubai - VARA: Virtual Assets Regulatory Authority regulates stablecoin issuance and services. Comprehensive licensing regime.

Abu Dhabi - ADGM: Financial Services Regulatory Authority oversees crypto activities in financial free zone.

Advantages: Strategic Middle East/Asia access, modern frameworks, government support for blockchain innovation.

Japan

Regulator: Financial Services Agency (FSA)

Framework: Payment Services Act amendments (effective June 2023)

Eligible Issuers: Banks, registered money transfer agents, trust companies

Requirements: Stable value maintenance, redemption mechanisms, asset segregation, robust AML/CFT

Other Emerging Markets

Brazil: Comprehensive crypto regulation with stablecoin provisions in development.

South Korea: Virtual assets regulated under Financial Transaction Reports Act.

Thailand: SEC crypto licensing with specific stablecoin rules.

Australia: Crypto asset regulation consultation ongoing, legislation expected.

Canada: Provincial securities regulators provide stablecoin guidance.

Stablecoin Custodial Licensing: Beyond Issuance

Why Custody Licenses Matter

Custodial services (holding cryptographic keys or controlling stablecoins for users) require separate authorization in most jurisdictions. Custody creates distinct risks warranting dedicated oversight.

Custody License Requirements by Jurisdiction

United States: State money transmitter licenses or federal banking charter. Requirements include minimum net worth, surety bonds, AML/CFT programs, cybersecurity measures.

Hong Kong: Provisions under Stablecoins Ordinance for custody services. Requirements include asset segregation, security measures, insurance/protections, operational controls.

Singapore: Digital Payment Token service provider license. Enhanced requirements for MAS-regulated stablecoin custody.

European Union: MiCA crypto-asset service provider authorization for custody/administration. Requirements include safeguarding arrangements, professional indemnity insurance, organizational requirements.

United Kingdom: Proposed framework includes safeguarding of qualifying cryptoassets with enhanced protections, segregation requirements, usage restrictions.

Key Custody Compliance Elements

Private Key Management: Secure generation, storage, backup/recovery, access restrictions.

Asset Segregation: Clear separation of client/custodian assets, accurate accounting, prohibition on commingling.

Cybersecurity: Threat detection, incident response, regular assessments, employee training.

Operational Resilience: Business continuity planning, redundancy systems, disaster recovery, regular testing.

Insurance: Professional indemnity coverage, adequate capital for operational risks, wind-down resources.

Strategic Multi-Jurisdictional Licensing Approach

Phased Global Licensing Strategy

Phase 1 - Foundation Building (6-12 months):

• Select primary jurisdiction based on business model, regulatory clarity, market access

• Obtain first license and build scalable compliance infrastructure

• Establish operational presence and banking relationships

Phase 2 - Strategic Expansion (12-24 months):

• Target complementary jurisdictions for customer access and strategic partnerships

• Leverage existing compliance programs, adapting to local requirements

• Focus on jurisdictions providing significant market opportunity

Phase 3 - Global Optimization (24+ months):

• Utilize passporting rights (EU MiCA) where available

• Establish partnerships in challenging markets

• Continuously optimize regulatory footprint based on business evolution

Jurisdiction Selection Criteria

Regulatory Clarity: Well-defined requirements with clear guidance reduce uncertainty and application risk.

Market Access: Target customer locations, growth potential, regional access (EU passporting), strategic alignment.

Operational Feasibility: Licensing timelines, costs, available service providers, banking infrastructure, talent availability.

Regulatory Reputation: Well-respected regulators signal quality, attract institutional partners, enhance credibility.

Scalability: Manageable compliance as operations scale, flexibility for business model changes, expansion pathways.

For multi-jurisdictional stablecoin licensing strategy and execution, contact Buckingham Capital Consulting: 020 7866 2512 | info@buckinghamcapitalconsulting.co.uk

Common Requirements Across All Stablecoin Licensing Frameworks

Despite jurisdictional variations, core requirements are consistent:

1. Full Reserve Backing

1:1 backing with fiat currency or high-quality liquid assets (bank deposits, short-term government securities, money market funds).

2. Asset Segregation

Complete separation of reserves from operational funds. Trust structures or statutory protections prioritizing holder claims.

3. Regular Audits and Attestations

Monthly attestations by independent auditors. Annual comprehensive audits of financials, controls, and regulatory compliance.

4. AML/CFT Compliance

Customer due diligence, transaction monitoring, sanctions screening, risk assessments, staff training.

5. Redemption Rights

Clear, enforceable par value redemption. Timely processing (1-5 business days typical). No unreasonable fees or restrictions.

6. Interest Prohibition

Most frameworks prohibit interest payments to holders, distinguishing stablecoins from deposit-taking.

7. Governance and Risk Management

Qualified management, clear structures, risk policies (credit, liquidity, market, operational, technology, legal, reputational), internal controls, board oversight.

8. Technical Compliance Capabilities

Systems for freeze/seizure per lawful orders, transaction monitoring, secure key management, audit trails, disaster recovery.

9. Transparency and Disclosure

Public reporting of circulation, reserve composition, attestations/audits, material changes, holder rights.

10. Adequate Capital

Beyond reserves: minimum paid-up capital, working capital for operations, wind-down resources.

Stablecoin License Application Timelines and Costs

Processing Time Expectations

Jurisdiction	Typical Timeline	Notes
United States	120 days maximum	Deemed approved if no response
Hong Kong	3-6 months	First batch early 2026
Singapore	4-8 months	Framework pending finalization
European Union	3-6 months	Varies by member state
United Kingdom	TBA (6-12 months est.)	Framework implementation 2026-27
Switzerland	6-12 months	Case-by-case
UAE (Dubai)	4-8 months	Varies by complexity
Japan	6-9 months	Established process

Best Practices for Successful Stablecoin License Applications

Pre-Application Preparation

1. Regulatory Gap Analysis: Assess current operations against requirements. Identify compliance gaps. Develop remediation roadmap.

2. Assemble Expert Teams: Specialized legal counsel (digital assets, regulatory), compliance professionals (AML/CFT, risk), technical experts (blockchain, security), qualified auditors (crypto-assets).

3. Design Compliance Frameworks: Governance structures, risk management policies, AML/CFT programs, operational controls, technology systems.

4. Establish Reserve/Custody Arrangements: Select qualified custodians, negotiate custody agreements, implement monitoring systems, design trust structures.

5. Build Technology Infrastructure: Compliance capabilities (monitoring, screening, reporting), secure key management, audit trails, cybersecurity controls.

6. Prepare Business Documentation: Detailed business plans, financial projections, risk assessments, scenario analysis.

7. Secure Adequate Capital: Meet minimum requirements plus buffer, operating capital for application period, contingency funding.

Regulator Engagement Strategy

Early Dialogue: Schedule pre-application meetings. Discuss business model and expectations. Identify potential concerns early. Clarify requirement interpretations.

Transparency and Responsiveness: Provide complete, accurate information. Respond promptly to questions. Acknowledge weaknesses with mitigation plans. Avoid overpromising.

Demonstrate Compliance Culture: Show commitment beyond minimums. Present robust policies and controls. Highlight qualified personnel. Evidence ongoing monitoring and improvement.

Application Submission Best Practices

Complete Applications: Submit all required documentation. Use regulator checklists. Have experts review pre-submission. Include supporting evidence.

Professional Presentation: Logical organization with clear navigation, professional formatting, executive summaries, glossaries for technical concepts.

Proactive Risk Addressing: Address potential concerns in applications. Explain novel business aspects. Demonstrate risk understanding and mitigation. Show consumer protection focus.

During Review Process

Maintain Open Communication: Respond promptly and completely to requests. Keep regulators informed of material changes. Be available for meetings. Maintain professional engagement.

Show Progress: Demonstrate implementation of planned controls. Provide evidence of ongoing preparation. Update on milestone achievements. Maintain momentum toward readiness.

Strategic Patience: Understand thorough review takes time. Follow up appropriately if delays occur. Maintain polite, professional demeanor. Escalate constructively if necessary.

Post-Licensing: Maintaining Compliance and Building Success

Ongoing Compliance Requirements

Continuous Monitoring: Automated reserve tracking (real-time), transaction monitoring (AML/CFT), performance metrics (circulation, redemptions, incidents), regulatory reporting systems.

Regular Audits: External attestations (monthly/quarterly), annual comprehensive audits, internal audit function, risk assessments (at least annually).

Staff Training: Comprehensive onboarding, regular compliance updates, regulatory change training, understanding assessments.

Technology Management: System maintenance and updates, security patching, performance monitoring, business continuity testing.

Regulatory Change Management: Monitor developments across jurisdictions, assess change impacts, implement required modifications, verify compliance pre-deadlines.

Proactive Regulator Engagement: Regular supervisor communication, material change notifications, annual meetings (even if not required), incident reporting with remediation.

Building Long-Term Success

Compliance as Competitive Advantage: Licensed status builds trust, enables institutional partnerships, provides market access, creates barriers to entry.

Operational Excellence: Robust systems and controls, qualified personnel, continuous improvement culture, incident learning and prevention.

Strategic Positioning: Maintain multiple jurisdictional licenses, leverage passporting rights, adapt to regulatory evolution, stay ahead of market requirements.

About Buckingham Capital Consulting: Your Stablecoin Licensing Partner Since 2013

Established 2013 | Over a Decade of Digital Asset Regulatory Expertise

Buckingham Capital Consulting has been at the forefront of crypto and stablecoin regulation since 2013, when the industry was in its infancy. We have guided clients through every phase of regulatory evolution, from the earliest frameworks to today's comprehensive licensing regimes across the United States, Hong Kong, Singapore, European Union, United Kingdom, and emerging markets.

Our Stablecoin Licensing Track Record

Since 2013, we have advised clients on:

• Multiple successful US stablecoin license applications under state and federal frameworks, including GENIUS Act compliance preparation

• Hong Kong HKMA license applications with comprehensive pre-application engagement and submission coordination

• Singapore MAS licensing for digital payment token services and stablecoin operations

• EU MiCA authorization applications across multiple member states leveraging our European regulatory network

• UK framework positioning preparing clients for 2026 implementation

• Multi-jurisdictional strategies enabling global operations with optimized regulatory footprints

• Reserve and custody arrangements with qualified custodians across all major markets

• Compliance program implementation covering AML/CFT, risk management, operational resilience, reporting

• Regulatory remediation successfully resolving issues and restoring good standing

Comprehensive Stablecoin Licensing Services

Global Regulatory Strategy: Jurisdictional selection and sequencing, timeline and resource planning, strategic flexibility for regulatory evolution, business model optimization.

License Application Management: Gap analysis and remediation, application preparation and documentation, regulator engagement and relationship management, response coordination and issue resolution, post-approval implementation.

Compliance Framework Design: AML/CFT and sanctions programs, reserve management and monitoring, risk governance frameworks, operational resilience and cybersecurity, regulatory reporting systems.

Reserve and Custody Solutions: Reserve structure design meeting regulatory requirements, qualified custodian selection, monitoring system implementation, trust structure development, optimization for compliance and efficiency.

Ongoing Regulatory Support: Continuous monitoring of global developments, impact assessment on operations, adaptation guidance for compliance, early warning of emerging risks/opportunities, strategic positioning advice.

Crisis Management: Rapid assessment and response, remediation strategy development, regulatory authority engagement, implementation oversight, restoration of good standing.

Why Infrastructure Builders Choose Buckingham Capital Consulting

Deep Expertise Since 2013: We witnessed and navigated every phase of crypto regulatory evolution. We understand regulatory thinking, have learned from challenges and successes, and apply insights to current engagements.

Global Network and Relationships: Established relationships with regulators, legal practitioners, and industry participants across all key jurisdictions provide insights and access driving successful outcomes.

Practical, Business-Focused Approach: We combine technical regulatory knowledge with pragmatic business understanding. Our advice balances compliance with commercial viability, appreciating real-world constraints of building stablecoin infrastructure.

Proven Success: Our clients have successfully obtained licenses and built compliant operations in the world's most demanding regulatory environments. We guide firms through challenging applications, complex issues, and successful global expansions.

Tailored Solutions: Each client's situation is unique. We customize our approach to your specific business model, target markets, development stage, resource constraints, and strategic objectives.

Long-Term Partnership: We view client relationships as long-term partnerships supporting your success throughout the regulatory journey from initial licensing through ongoing compliance and expansion.

Industries We Serve

Stablecoin Issuers: Startups launching new stablecoins to established institutions entering the market.

Infrastructure Providers: Platforms like Bridge building custody, settlement, and payment solutions.

Crypto Exchanges: Entities listing or trading stablecoins across multiple jurisdictions.

Financial Institutions: Banks and payment institutions issuing, custodying, or transacting in stablecoins.

Fintech Companies: Firms integrating stablecoins into products requiring regulatory guidance.

Institutional Investors: Asset managers and investors seeking compliant stablecoin exposure.

Technology Companies: Blockchain infrastructure, wallet, or payment system developers.

Our Approach

Consultative Partnership: We invest time understanding your business, objectives, challenges, and constraints. Our recommendations align with your strategic goals.

Proactive Communication: Regular updates on relevant developments, early issue identification, transparent status reporting.

Transparent Pricing: Clear scoping with no hidden fees. You understand what you're paying for and expected outcomes.

Responsive Support: We're available when you need us, understanding that licensing timelines can compress and issues arise unexpectedly.

Knowledge Transfer: We help you build internal capabilities, not just do things for you. Your team gains knowledge to manage ongoing compliance.

Continuous Improvement: We learn from every engagement and refine our approaches. You benefit from our growing expertise and evolving best practices.

Why Act Now?

Regulatory Windows Are Open: The GENIUS Act is live, Hong Kong is issuing licenses, MiCA is fully applicable, and other jurisdictions are following suit. Early movers gain competitive advantages.

Market Opportunity Is Growing: Stablecoin transaction volumes exceed traditional payment networks. Institutional adoption is accelerating. Infrastructure needs are expanding rapidly.

Competition Is Intensifying: Well-funded competitors are securing licenses. Market position is being established. Delay creates competitive disadvantage.

Regulatory Standards Are Rising: As frameworks mature, requirements become more stringent. Entry barriers increase over time. Today's standards are tomorrow's minimum.

First-Mover Advantages Matter: Licensed operators gain institutional partnerships, banking relationships, market credibility, and operational experience that create sustainable competitive moats.

What Success Looks Like

With proper guidance and execution, you can achieve:

Licensed Operations Across Key Markets: US, Hong Kong, EU, Singapore, UK, and other strategic jurisdictions.

Institutional-Grade Compliance: Frameworks meeting or exceeding regulatory expectations, enabling partnerships with major financial institutions.

Operational Excellence: Robust systems, qualified teams, efficient processes, and sustainable business models.

Market Leadership: Competitive positioning through compliance, reputation, and operational capability.

Long-Term Sustainability: Adaptable infrastructure positioned for regulatory evolution and business growth.

Next Steps: Partner with Buckingham Capital Consulting

Initial Consultation: We begin with a comprehensive assessment of your business model, target markets, current compliance status, and strategic objectives. This consultation identifies optimal licensing pathways and realistic timelines.

Strategic Roadmap Development: Based on the assessment, we develop a detailed roadmap covering jurisdictional priorities, application sequencing, resource requirements, timeline projections, and success metrics.

Implementation Support: Our team guides you through every step including gap remediation, documentation preparation, regulator engagement, application submission, issue resolution, and approval achievement.

Ongoing Partnership: Post-licensing, we provide continuous support for ongoing compliance, regulatory monitoring, framework adaptation, expansion into new jurisdictions, and crisis management if needed.

Contact Buckingham Capital Consulting Today

Don't navigate the complex world of stablecoin licensing alone. With over a decade of experience since 2013, comprehensive expertise across all major jurisdictions, proven success with challenging applications, and deep commitment to client success, Buckingham Capital Consulting is the partner you need.

The stablecoin market is transforming global finance. Regulatory clarity has arrived. The opportunity is substantial. And the time to act is now.

For stablecoin licensing strategy, application management, and compliance advisory:

Phone: 020 7866 2512

Email: info@buckinghamcapitalconsulting.co.uk

Website: www.buckinghamcapitalconsulting.com

Schedule your confidential consultation today and take the first step toward compliant, globally licensed stablecoin operations.

Frequently Asked Questions: Stablecoin Licensing

How long does it take to obtain a stablecoin license?

Timelines vary by jurisdiction: US (120 days maximum under GENIUS Act), Hong Kong (3-6 months), Singapore (4-8 months when framework is live), EU (3-6 months), UK (TBA, estimated 6-12 months when regime launches). Total time from initial planning to approval typically ranges 6-18 months depending on jurisdiction and preparation level.

What is the minimum capital required for stablecoin licensing?

Requirements vary significantly: US (depends on pathway, typically $1-10 million+), Hong Kong (HK$25 million or ~$3.2 million USD), Singapore (S$1 million or 50% of operating expenses), EU (varies by member state and stablecoin type), UK (TBA when framework is finalized). Beyond minimum capital, expect substantial additional investment in compliance infrastructure, technology, and professional services.

Can I operate in multiple jurisdictions with one license?

The EU MiCA framework offers passporting rights, allowing operation across all 27 member states with a single authorization. Other jurisdictions require separate licenses. However, obtaining one well-respected license (e.g., US, Hong Kong, EU) can facilitate subsequent applications elsewhere by demonstrating regulatory credibility and operational capability.

Do I need separate licenses for issuance and custody?

Most jurisdictions require separate authorization for custodial services. In the US, custody typically requires state money transmitter licenses. Hong Kong, Singapore, EU, and UK all have distinct custody licensing requirements. If your business model includes both issuance and custody, plan for dual licensing in most markets.

What happens if I operate without a license?

Operating without required licenses exposes firms to significant penalties including criminal charges and imprisonment, substantial fines (€15 million or 3% of turnover under MiCA), cease and desist orders, asset seizures, personal liability for executives, and permanent market bans. Additionally, unlicensed operations cannot access banking relationships, institutional partnerships, or compliant distribution channels.

Can foreign stablecoin issuers access US markets?

Under the GENIUS Act, foreign issuers can access US markets if they are from jurisdictions with comparable regulatory frameworks (determined by Treasury Secretary), register with the OCC, hold reserves in US financial institutions sufficient for US customer liquidity, and demonstrate capability to comply with US lawful orders including sanctions and asset freezes.

How much does stablecoin licensing cost?

Total first-year costs per jurisdiction typically range $500,000 to $3,000,000+ including application/regulatory fees ($10,000-$100,000+), legal and advisory services ($200,000-$1,000,000+), initial audits and attestations ($50,000-$200,000), technology implementation ($200,000-$1,000,000+), and setup costs. Annual ongoing compliance costs range $300,000 to $2,000,000+ per jurisdiction.

What are the reserve requirements for stablecoins?

All major jurisdictions require 1:1 backing with fiat currency or high-quality liquid assets. Permitted assets typically include bank deposits, short-term government securities (Treasury bills), repurchase agreements backed by government securities, government money market funds, and central bank reserves. Most frameworks prohibit equity investments, corporate bonds, crypto-assets, or other risky holdings.

Can stablecoins pay interest to holders?

Most frameworks prohibit interest payments to stablecoin holders to distinguish stablecoins from deposit-taking activities. The US GENIUS Act, Hong Kong Ordinance, and proposed UK framework all prohibit interest payments. Issuers typically retain interest earned on reserves as their revenue model. The EU MiCA has similar restrictions.

How do I choose which jurisdiction to apply in first?

Consider regulatory clarity and maturity, target customer locations, market size and growth potential, licensing timeline urgency, application success probability, operational costs and complexity, regulatory reputation and credibility, and strategic expansion pathways. For most infrastructure builders, the US, Hong Kong, or EU represent optimal starting points based on market access, regulatory clarity, and credibility.

What is the difference between ARTs and EMTs under MiCA?

Asset-Referenced Tokens (ARTs) maintain stable value by referencing multiple assets (multiple currencies, commodities, basket of assets). E-Money Tokens (EMTs) are pegged to a single fiat currency. EMTs must be issued by credit institutions or e-money institutions and face restrictions on reserve location (must remain in EU). Both may be designated "significant" with enhanced oversight.

Do I need a lawyer for stablecoin licensing applications?

While not legally required, specialized legal counsel is practically essential for successful applications. Stablecoin licensing involves complex regulatory requirements, technical documentation standards, regulator engagement strategies, and compliance framework design. Experienced advisors significantly increase success probability and accelerate timelines. Most successful applicants invest $200,000-$1,000,000+ in professional advisory services.

How often are reserves audited?

Requirements vary by jurisdiction but typically include monthly attestations by independent qualified auditors examining reserve adequacy and compliance, quarterly reviews for larger issuers, and annual comprehensive audits of financial statements, internal controls, and regulatory compliance. Some jurisdictions also require real-time or daily reconciliation with automated monitoring systems.

What AML/CFT requirements apply to stablecoin issuers?

All jurisdictions require comprehensive AML/CFT programs including customer due diligence and Know Your Customer (KYC) procedures, transaction monitoring and suspicious activity reporting, sanctions screening and compliance, risk assessments of products and customer types, record keeping and reporting, staff training programs, and independent testing and audits. Requirements align with Financial Action Task Force (FATF) international standards.

Can algorithmic stablecoins be licensed?

Most current frameworks exclude algorithmic or under-collateralized stablecoins. The US GENIUS Act, Hong Kong Ordinance, Singapore framework, and EU MiCA all require full reserve backing with fiat or equivalent assets. Algorithmic stablecoins relying on arbitrage, code, or crypto-asset backing generally do not qualify. This reflects regulatory caution following failures like TerraUSD.

What happens if my stablecoin loses its peg?

Licensed issuers must maintain 1:1 reserve backing at all times. If the peg is threatened, issuers must use reserves to restore parity through redemptions or market operations. Persistent de-pegging indicates reserve inadequacy or operational failures, triggering regulatory intervention potentially including enhanced supervision, restrictions on new issuance, mandatory reserve additions, or license suspension/revocation. This is why overcollateralization is often expected.

Conclusion: The Future of Stablecoins Is Licensed, Compliant, and Global

The stablecoin industry has reached a defining moment. Regulatory clarity has arrived across major markets. Institutional adoption is accelerating. And the infrastructure for compliant, globally-scaled operations is being built today.

For serious market participants, stablecoin licensing is no longer optional. It is the foundation for sustainable growth, institutional partnerships, and long-term market leadership. The regulatory frameworks established in 2025 will define winners and losers for the next decade.

Those who move decisively to obtain licenses, build robust compliance infrastructure, and establish operations across key jurisdictions will capture the enormous opportunity ahead. Those who delay, cut corners, or underinvest in compliance will find themselves unable to compete as standards rise and market expectations evolve.

The choice is clear: embrace regulation as a strategic advantage and competitive moat, or watch from the sidelines as licensed operators capture market share, institutional partnerships, and user trust.

Buckingham Capital Consulting has guided clients through this journey since 2013. We have witnessed regulatory evolution from its earliest days. We have built relationships with regulators globally. We have learned what works and what doesn't. And we have helped numerous clients achieve successful licensing outcomes across the world's most demanding jurisdictions.