Stablecoins · October 2026
[email protected]
WhatsApp +44 7563 115980
Telegram @buckinghamcapital
A stablecoin licence lets a firm issue a token backed one for one by reserves.
The route to an issuer licence in any of these markets. Statutory periods are the regulators’; the other times are our planning figures.
Government charges and capital for an issuer; reserves are held for holders and are not capital. Hong Kong and Singapore are left out where the regulator’s figure could not be confirmed.
| Item | United States | European Union | United Kingdom |
|---|---|---|---|
| Regulator application fee | Set by the federal and state regulators under the GENIUS Act rules | Set by the home member state regulator | £11,260 (FCA category 6) |
| Initial capital | Set by the regulators’ capital rules under the Act | €350,000 initial capital for an electronic money institution | Highest of £350,000, the fixed overheads requirement and a K-factor of 1% of coins in issue |
| Annual regulator or supervisory fee | Set by the regulators | Set by the home regulator | FCA periodic fees |
| Audit | Monthly reserve report examined by a registered public accounting firm, certified each month by the chief executive and finance director | Annual audit of the e-money institution under the home regulator’s rules | Prudential reporting under the FCA’s cryptoasset prudential rules (PS26/12) |
| Required roles | An anti-money laundering programme with a designated officer to supervise it; the issuer is a financial institution under the Bank Secrecy Act | A compliance officer and an anti-money laundering officer | A compliance officer and a money laundering reporting officer |
| Insurance, bond or reserves | Reserves of at least one dollar per coin in cash, insured deposits, short Treasury bills, Treasury repurchase agreements and government money market funds | At least 30% of funds received held at credit institutions; the rest in highly liquid, low-risk instruments | Backing assets on statutory trust, separately for each coin |
Who can issue in each jurisdiction, and where each regime stands today.
| Jurisdiction | Issuer licence | Where it stands |
|---|---|---|
| United States | Permitted payment stablecoin issuer: a bank subsidiary, a federal issuer licensed by the OCC, or a state issuer | The GENIUS Act became law on 18 July 2025. The regulators’ rules are being finalised, and the regime applies by 18 January 2027 at the latest. |
| European Union | E-money token issuer, authorised as an electronic money institution or a credit institution | MiCA has applied to stablecoins since 30 June 2024. An e-money institution authorised in one member state can offer its token across the EU. |
| United Kingdom | FCA authorisation to issue qualifying stablecoins | Applications run from 30 September 2026 to 28 February 2027. The regime starts on 25 October 2027. |
| Hong Kong | HKMA licence for fiat-referenced stablecoin issuers | The Stablecoins Ordinance has been in force since 1 August 2025. The HKMA granted the first two licences on 10 April 2026. |
| Singapore | Licensed issuer under the MAS stablecoin framework, proposed | MAS consulted on the legislative amendments from 1 September to 16 October 2026. No start date has been set. |
Tell us where you are and where you want to be.
[email protected]
WhatsApp +44 7563 115980
Telegram @buckinghamcapital
In the US the GENIUS Act applies by 18 January 2027; in the EU an e-money institution issues under the Markets in Crypto-Assets Regulation; in the UK the Financial Conduct Authority (FCA) requires £350,000 of capital and an £11,260 fee, applications closing 28 February 2027.
We build licensed stablecoin businesses: the issuer licence, the reserve banking and custody, the technology and the team, in the United States, the European Union, the United Kingdom and Hong Kong, with Singapore to follow as its licence opens.
A stablecoin, in regulatory terms, is a token designed to hold a stable value against one fiat currency, such as the US dollar or the euro, and backed by reserves the issuer holds for holders. Regulators treat these tokens as payment instruments close to electronic money, so the issuer licence looks like an e-money licence with tighter rules on reserves, redemption and disclosure.
The licence is separate from the permissions the coin’s distributors need. An exchange, wallet or payment firm that holds, transfers or exchanges a stablecoin for customers needs its own crypto-asset service provider authorisation in the EU, a cryptoasset authorisation in the UK, or money transmitter licences in each US state. A crypto registration alone, such as a virtual asset service provider registration, does not permit issuance in any of the five jurisdictions below.
Five questions decide the first licence; most issuers that go global hold more than one, each with its own reserves.
Only a permitted payment stablecoin issuer: a subsidiary of an insured bank, a federal qualified issuer licensed by the Office of the Comptroller of the Currency (OCC), or a state qualified issuer.
At least one dollar of reserves for every coin issued, held only in cash, insured deposits, Treasury bills with 93 days or less to maturity, short repurchase agreements backed by Treasuries, and government money market funds.
The issuer publishes its reserves every month. A registered public accounting firm examines each report, and the chief executive and finance director certify it.
A state issuer with more than $10 billion of coins in circulation moves to federal supervision.
From 18 July 2028, US platforms may only offer stablecoins issued by a permitted issuer.
A federal regulator must decide a substantially complete application within 120 days of receiving it.
The Act takes effect on the earlier of 18 January 2027, 18 months after it was approved on 18 July 2025, or 120 days after the regulators issue final regulations.
A state qualified issuer with no more than US$10 billion outstanding may stay under a substantially similar state regime; above that it moves to federal oversight within 360 days.
A subsidiary of an insured credit union can also be approved. A public company not predominantly engaged in financial activities, and a non-US company of that kind, may issue only with a unanimous vote of the Stablecoin Certification Review Committee.
Coins and currency and Federal Reserve balances, demand deposits at insured institutions, Treasuries issued with or having 93 days or less to maturity, overnight repurchase and reverse repurchase agreements backed by Treasuries, government money market funds, and tokenised forms of these.
A permitted issuer may not pay holders any form of interest or yield on its payment stablecoins.
The issuer has the technical ability, policies and procedures to block, freeze and reject specific or impermissible transactions that break federal or state law.
An issuer with more than US$50 billion outstanding that does not report to the SEC prepares annual financial statements under US generally accepted accounting principles.
An application that is not decided within 120 days of being complete is deemed approved. A denial is explained in writing and the applicant can ask for a hearing.
Section 5(h) preempts state charter and licensing requirements for a federal qualified issuer and for an approved subsidiary of an insured bank or credit union.
A foreign issuer can serve US customers if Treasury finds its home regime comparable, it registers with the OCC, it holds reserves in a US financial institution sufficient for US customers’ liquidity demands, and its home country is not under comprehensive US sanctions or designated of primary money laundering concern.
Only a firm supervised by a federal or state banking regulator, or by the SEC or CFTC, may hold the reserves, stablecoins used as collateral or the private keys used to issue them.
The OCC published the first final rule on 23 October 2026, effective 18 January 2027. Proposals are out from the FDIC (10 April 2026), the NCUA (18 May 2026), Treasury (18 August 2026) and the Federal Reserve (29 September 2026), with FinCEN and OFAC proposing the AML and sanctions programme rules on 10 April 2026.
Treasury proposed the principles for a substantially similar state regime on 3 April 2026 and issued interim certification forms on 30 September 2026. Each state regulator certifies its regime no later than one year after the Act takes effect.
An e-money token may be issued only by an electronic money institution or a credit institution, after it notifies its regulator and publishes a white paper.
Holders can redeem at any time, at par, in ordinary funds.
At least 30% of the funds received is held in separate accounts at credit institutions. The rest is invested in highly liquid, low-risk instruments in the same currency.
Tokens the EBA classes as significant carry additional requirements and come under EBA supervision.
Redemption of an e-money token carries no fee. Neither the issuer nor a crypto-asset service provider may grant interest in relation to e-money tokens.
The issuer notifies its crypto-asset white paper to its regulator at least 20 working days before publishing it.
A token is classed as significant when it meets at least three criteria, among them more than 10 million holders, more than €5 billion issued or held in reserve, or more than 2.5 million transactions and €500 million a day.
An e-money institution issuing one follows MiCA’s reserve rules and own funds rules for asset-referenced tokens, with an independent audit of the reserve every six months.
An asset-referenced token, or an e-money token in a non-EU currency, used above 1 million transactions and €200 million a day as a means of exchange in a single currency area stops issuance and files a plan within 40 working days.
The issuer holds own funds of at least the highest of €350,000, 2% of the average reserve of assets and a quarter of the previous year’s fixed overheads.
National transitional periods for crypto-asset service providers ended on 1 July 2026 at the latest, so any firm offering crypto services in the EU now needs MiCA authorisation.
The EBA’s transition for service providers whose e-money token services are payment services ended on 2 March 2026. Its Opinion of 12 February 2026 sets the conditions on which firms awaiting a payment services authorisation may continue; others are told to stop.
The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (SI 2026/102) bring stablecoin issuance into FCA regulation from 25 October 2027.
The FCA’s final rules, PS26/10, were published in June 2026.
Backing assets are held on statutory trust, separately for each coin, in the coin’s own currency, with a minimum held as on-demand deposits.
Holders are paid by the end of the next business day.
Applications are open through the FCA from 30 September 2026 to 28 February 2027. A firm not authorised by the start date must wind down its UK business.
Own funds of at least the highest of a permanent minimum of £350,000, the fixed overheads requirement and a K-factor of 1% of coins in issue, cut from the 2% the FCA first proposed (PS26/12).
£11,260: issuing a qualifying stablecoin is a category 6 application under FEES 3 Annex 1.
HM Treasury made the Cryptoassets Regulations on 4 February 2026.
On top of its on-demand deposit requirement, the issuer holds core backing assets of at least the higher of 5% of the backing pool and its highest daily redemption percentage over the past 180 redemption days.
A signed acknowledgement letter from each custodian, reviewed at least annually, and no more than 20% of the backing pool with group custodians unless the firm shows the limit would be disproportionate.
Backing assets and coins in circulation updated at least every three months, with an annual independent reasonable assurance review of the 1:1 backing.
Interest or income from the backing pool may not be passed to holders, directly or through a third party.
From 25 October 2027 each activity needs its own FCA permission, with its own permanent minimum capital under the cryptoasset prudential rules. A firm holding several permissions holds the highest.
| Business model | Permission | Permanent minimum capital |
|---|---|---|
| UK issuer | Issuing a qualifying stablecoin | £350,000 |
| Custodial wallet | Safeguarding qualifying cryptoassets | £150,000 |
| Exchange | Operating a qualifying cryptoasset trading platform | £150,000 |
| Staking service | Arranging qualifying cryptoasset staking | £150,000 |
| Principal trading desk | Dealing in qualifying cryptoassets as principal | £750,000 |
| Broker | Dealing as agent, or arranging deals, in qualifying cryptoassets | £75,000 |
Issuing a fiat-referenced stablecoin in Hong Kong requires an HKMA licence under the Stablecoins Ordinance.
The HKMA granted the first two licences on 10 April 2026, to Anchorpoint Financial and HSBC.
Reserve management, redemption arrangements, governance, risk management and financial crime controls, before it grants a licence.
Anyone who issues a fiat-referenced stablecoin in Hong Kong, issues one anywhere that references the Hong Kong dollar, or actively markets such an activity to the Hong Kong public.
Paid-up share capital of at least HK$25 million, or other financial resources the HKMA approves as equivalent.
The HKMA expects senior management and key personnel to be based in Hong Kong.
A licensee may engage only permitted offerors: licensees, authorised institutions, stored value facility licensees, SFC-licensed virtual asset trading platforms and Type 1 licensed corporations.
Licensed stablecoins are non-interest bearing.
MAS published its stablecoin framework in August 2023 and consulted from 1 September to 16 October 2026 on the legislative amendments that implement it.
Licensed issuers of single-currency stablecoins pegged to the Singapore dollar or a G10 currency, under the MAS framework for MAS-regulated stablecoins.
The consultation closed on 16 October 2026. MAS has not set a start date.
Under the framework MAS finalised on 15 August 2023, issuers return par value within five business days of a redemption request.
Minimum base capital and liquid assets, and disclosure of the value-stabilising mechanism, holder rights and reserve audit results.
Only issuers meeting every requirement may apply for the MAS-regulated stablecoin label; misrepresenting a token with it may lead to penalties.
Under the Stablecoin Act the Bank of Canada will register non-financial issuers of stablecoins to Canadians, supervise their compliance, monitor issuance and redemption risks and take enforcement action.
The Department of Finance is developing the regulations, with proposed regulations published in Part I of the Canada Gazette.
Firms dealing in virtual currency for clients in Canada already register with FINTRAC as money services businesses. See Canada MSB registration.
An issuer licence covers issuance and redemption. The firms that carry the coin to customers need their own permissions.
| Market | Permission for firms that hold, transfer or exchange the coin | Where to read more |
|---|---|---|
| United States | FinCEN money services business registration and a money transmitter licence in each state that requires one; California’s Digital Financial Assets Law licence for digital asset business with residents from 1 July 2026 | US money transmitter licence by state |
| European Union | Crypto-asset service provider authorisation under MiCA | MiCA CASP authorisation |
| United Kingdom | FCA cryptoasset authorisation for the relevant activity from 25 October 2027 | UK cryptoasset authorisation |
| New York | A BitLicense or a limited purpose trust charter for virtual currency business with New York residents | New York BitLicense |
| Canada | FINTRAC money services business registration for dealing in virtual currency, as a foreign MSB where the firm has no place of business in Canada | Canada MSB registration |
One team from the licence to launch.
The right jurisdiction for your coin and your customers, and the application through to approval: e-money institution, US issuer, FCA or HKMA.
Reserve accounts, custody for reserve assets and the trust arrangements, opened alongside the application.
Issuance, redemption and reserve reporting systems, ready for launch.
We assemble your team: directors, compliance officer, MLRO and treasury.
The licences your partners need to hold, transfer or exchange your coin: MiCA crypto-asset service provider, UK cryptoasset authorisation and US money transmitter licences.
Monthly reserve reporting, audits, redemption testing and the ongoing obligations of each regulator.
This guide is general information, not legal advice. Requirements and fees change, and the regulator’s own publications take precedence.
It depends on the currency of the coin and where its holders are. A euro coin is issued under MiCA through an e-money institution with €350,000 of initial capital; a US dollar coin offered to US customers needs a permitted issuer under the GENIUS Act.
In the European Union, yes: an authorised electronic money institution can issue e-money tokens after notifying its regulator and publishing a white paper. In the United Kingdom, issuing qualifying stablecoins requires a separate FCA authorisation from 25 October 2027.
On 25 October 2027. Applications are open from 30 September 2026 to 28 February 2027, with a £11,260 application fee and a £350,000 permanent minimum capital requirement.
In the UK, the highest of £350,000, the fixed overheads requirement and 1% of coins in issue; in the EU, €350,000 of initial capital for an e-money institution. US capital is set by the regulators’ rules under the GENIUS Act.
On the earlier of 18 January 2027 or 120 days after the federal regulators issue final regulations. From 18 July 2028, US platforms may only offer payment stablecoins from a permitted issuer.
Firms that hold, transfer or exchange stablecoins for customers usually need a crypto-asset service provider licence in the EU, a cryptoasset authorisation in the UK, or money transmitter licences in the US, where state fees run from US$100 to US$10,000.
No. The GENIUS Act bars permitted issuers from paying interest or yield, MiCA bars interest on e-money tokens by issuers and service providers, the FCA bars passing backing asset income to holders, and Hong Kong licensed stablecoins are non-interest bearing.
Yes, if Treasury finds its home regime comparable, it registers with the OCC, it holds enough reserves in a US financial institution for US customers, and its home country is not under comprehensive US sanctions.
Usually. In the UK, safeguarding cryptoassets is its own permission with £150,000 of permanent minimum capital; under the GENIUS Act only supervised firms may hold reserves or issuing keys; in the EU, custody is a crypto-asset service.
Paid-up share capital of at least HK$25 million, or other financial resources the HKMA approves as equivalent, with senior management and key personnel expected to be based in Hong Kong.
Cited in the sections above
What it costs in the first year. Sources: GENIUS Act, Public Law 119-27; FCA PS26/12, June 2026; FCA: application fees; FCA Handbook FEES 3 Annex 1.
United States. Sources: GENIUS Act, sections 3, 4, 5, 10 and 18; OCC final rule, 91 FR 67000; FDIC; NCUA; Treasury; Federal Reserve; FinCEN and OFAC; Treasury principles; Committee forms.
European Union. Sources: MiCA Article 23; Article 35; Article 43; Article 49; Article 50; Article 51; Article 58; Article 143; EBA Opinion, 12 February 2026.
United Kingdom. Sources: SI 2026/102, made 4 February 2026; FCA PS26/10.
UK permissions and minimum capital. Sources: FCA PS26/12, CRYPTOPRU 4.2.1R.
Hong Kong. Sources: HKMA: Explanatory Note on Licensing of Stablecoin Issuers.
Singapore. Sources: MAS: framework finalised, 15 August 2023.
Canada. Sources: Bank of Canada: stablecoins; FINTRAC: money services businesses.
The licences distributors need. Sources: California Financial Code 3201; GENIUS Act.
Stablecoins · October 2026
Stablecoins · July 2026
MiCA and crypto EU · May 2026