Stablecoin Licences by Country, 2027: Reserves, Capital, Interest and Timelines in Ten Markets

Stablecoin licences by country: the short answer

Ten markets now have a licensing route, in force or in draft, for companies that issue stablecoins: tokens that hold a stable value against a currency such as the US dollar, backed by reserves. The European Union, Hong Kong, the UAE and Japan license issuers under rules already in force. The United States regime takes effect on 18 January 2027 and the United Kingdom regime on 25 October 2027, with the FCA application window open now. Canada published draft regulations on 24 October 2026, Singapore consulted on an issuer licence until 16 October 2026, Kenya has placed issuance with its central bank, and Brazil regulates stablecoins through the service providers that offer them.

Wherever the detailed rules are set, the core is the same: reserves at least equal to the coins in circulation, held apart from the issuer's own money in cash, deposits and short-dated government debt; redemption at par, meaning face value; and public reserve reporting. The UK, the EU, the US, Hong Kong and the UAE central bank bar issuers from paying interest for holding the coin, and the Canadian and Singapore drafts do the same. The UK and Canada allow rewards linked to using a coin rather than holding it.

Three things differ, and they decide where to issue. Who may issue: the EU limits single-currency tokens to e-money institutions and banks, while the US, the UK, Hong Kong and Canada license non-bank companies directly. Capital: fixed minimums run from £350,000 in the UK and €350,000 in the EU to AED 15 million for a dirham token issuer licensed by the UAE central bank and HK$25 million in Hong Kong. Redemption: one business day in the UK, Hong Kong and the UAE, three in Canada, five under Singapore's 2023 framework, and at any time in the EU. The firm's stablecoin licensing practice files applications in each of them.

Summary table: stablecoin regulation by country

The issuer regulator, the position at 30 October 2026 and the next date that matters in each market.

Capital and redemption compared

Capital is held on top of the reserve, which belongs to holders and does not count towards it. Redemption is how quickly a returned coin must be paid at face value.

Japan, Brazil and Kenya set these points through issuer type, service provider rules and regulations respectively.

United Kingdom: FCA authorisation from 25 October 2027

The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 (SI 2026/102), made on 4 February 2026, make issuing a qualifying stablecoin in the UK a regulated activity, which needs FCA authorisation once the regime starts on 25 October 2027, the date the FCA expects. The FCA published its final rules on 30 June 2026: PS26/10 on issuance, backing, redemption and disclosure, and PS26/12 on capital.

The FCA application window opened on 30 September 2026 and closes on 28 February 2027. The FCA expects to decide window applications before the start date, and a window applicant still waiting then can keep operating until its application is decided; later applications are not expedited. Issuers that HM Treasury recognises as systemic are regulated jointly by the FCA and the Bank of England.

The permission covers issuing in the UK; a coin issued overseas can still be held and traded through FCA-authorised firms with their own crypto permissions. Our page on UK cryptoasset authorisation sets out the application file.

European Union: MiCA e-money tokens and asset-referenced tokens

The Markets in Crypto-Assets Regulation (MiCA) has applied to stablecoin issuers since 30 June 2024. A token that references one official currency, such as the euro or the dollar, is an e-money token (EMT) and may be issued only by a credit institution or an electronic money institution (EMI). A token that references anything else, such as a basket of currencies or gold, is an asset-referenced token (ART). Authorisation in one member state covers the European Economic Area.

On 14 October 2026 the European Banking Authority (EBA) classified USDC, issued by Circle Internet Financial Europe SAS, as the first significant EMT of the 45 notified under MiCA. From 12 November 2026 the EBA supervises its own funds, reserve, liquidity and recovery and redemption plans, with the French regulator, the ACPR, keeping governance. On 8 October ESMA, the EU markets authority, said crypto-asset service providers (CASPs) should stop providing services in stablecoins that do not comply with MiCA, and asked national regulators to require existing exposures to be cleared within three months, by 8 January 2027.

A token in a non-EU currency stops issuing once daily use as a means of exchange in one currency area exceeds 1 million transactions and €200 million. The MiCA transitional periods for service providers ended on 1 July 2026. Our guide to the MiCA stablecoin licence covers the EMI and ART applications in full.

United States: the GENIUS Act from 18 January 2027

The GENIUS Act, Public Law 119-27, was signed on 18 July 2025 and takes effect on the earlier of 18 January 2027 or 120 days after the federal regulators issue final rules. The Office of the Comptroller of the Currency (OCC), the federal bank regulator, issued its final rule on 21 October 2026, effective 18 January 2027. It adds a new 12 CFR part 15 on reserve assets, redemption, risk management, audits and reports, custody, applications, and capital and operational backstops. Anti-money laundering and sanctions rules follow in a separate rulemaking with Treasury.

A permitted issuer is a subsidiary of an insured bank or credit union, approved by the parent's federal regulator; a federal qualified issuer approved by the OCC, which can be a non-bank company; or a state qualified issuer under a state regime certified as substantially similar, open up to $10 billion outstanding, with 360 days to move to federal oversight above that. A regulator decides a substantially complete application within 120 days.

From 18 July 2028, three years after enactment, exchanges, wallets and other digital asset service providers may offer people in the US only coins from permitted issuers or qualifying foreign issuers. State licensing for distribution, such as the New York BitLicense, sits alongside the issuer route, and our guide to GENIUS Act compliance covers each rule and proposal.

Canada: Bank of Canada registration under the Stablecoin Act

The Stablecoin Act received royal assent in March 2026. The Department of Finance published the draft Stablecoin Regulations in the Canada Gazette, Part I on 24 October 2026, with comments open for 60 days to 23 December 2026, and intends both to come into force in autumn 2027.

From then, an issuer that is not a financial institution registers with the Bank of Canada before issuing; the Act does not apply to financial institutions that issue stablecoins. The Minister of Finance has 60 days from receiving each application to decide whether to run a national security review. An issuer already active at the start can continue if it applies within 30 days.

Issuers also send the Bank of Canada a monthly report with an accountant's opinion on the reserve.

Hong Kong: HKMA licence under the Stablecoins Ordinance

The Stablecoins Ordinance (Cap. 656) took effect on 1 August 2025. A licence is needed to issue a fiat-referenced stablecoin in Hong Kong, to issue a Hong Kong dollar stablecoin anywhere, and to actively market a stablecoin issue to the Hong Kong public. On 10 April 2026 the Hong Kong Monetary Authority (HKMA) granted the first two issuer licences, to Anchorpoint Financial Limited and The Hongkong and Shanghai Banking Corporation Limited.

The applicant is a Hong Kong company or an authorised institution under the Banking Ordinance, with fit and proper management; the HKMA asks applicants to contact it before filing.

Our guide to Hong Kong payment and crypto licences sets the issuer licence beside the stored value facility, money service operator and trading platform licences.

Singapore: a dedicated stablecoin issuance licence

The Monetary Authority of Singapore (MAS) finalised its stablecoin framework on 15 August 2023 for single-currency stablecoins pegged to the Singapore dollar or a G10 currency and issued in Singapore. Its consultation paper P015-2026, published on 1 September 2026 and closed on 16 October 2026, proposes amendments to the Payment Services Act 2019 to put the framework into law.

The paper proposes a licence class for stablecoin issuance, and only a licensee may call its token an MAS-regulated stablecoin. A licensed issuer may not carry on other regulated business beyond services for its own coins, a Singapore company issuing outside the framework needs a major payment institution licence, and banks would issue through a separate non-bank company. MAS also seeks views on a minimum share of reserves in cash and deposits and on issuance or holding caps.

United Arab Emirates: Central Bank payment tokens and VARA in Dubai

The Central Bank of the UAE (CBUAE) regulates stablecoins as payment tokens under its Payment Token Services Regulation, in force since 31 August 2024. A dirham token may be issued only by a CBUAE-licensed issuer and only to UAE residents; a foreign-currency token from a registered foreign issuer may be used in the UAE only to buy virtual assets. Banks issue through a subsidiary, algorithmic stablecoins are banned, and no interest or other benefit may be paid for how long a customer holds a token. The financial free zones run their own regimes.

In Dubai, the Virtual Assets Regulatory Authority (VARA) licenses the issue of fiat-referenced virtual assets as a Category 1 issuance under its fiat-referenced virtual asset rules, approving each token. These tokens serve only to buy and sell virtual assets, not to pay for goods and services in the UAE, and dirham-pegged tokens stay with the CBUAE.

Our Dubai VARA licence guide covers the service provider licence within which the issuance activity sits.

Japan: electronic payment instruments under the Payment Services Act

Japan regulates fiat-backed stablecoins as electronic payment instruments under the Payment Services Act (Act No. 59 of 2009), as amended by Act No. 61 of 2022. The category covers currency-denominated digital assets that can pay unspecified persons and move electronically, and specified beneficial interests in a trust, where the money in trust is managed as bank deposits.

Issuers are banks, registered funds transfer service providers and trust companies. A firm that buys, sells, exchanges or holds these instruments for others registers as an electronic payment instruments service provider, while an issuer may do so for its own coins on notification. The Prime Minister's powers under the Act are delegated to the Commissioner of the Financial Services Agency (FSA).

Reserve composition, capital and redemption detail sit in Cabinet Office Orders and FSA guidelines under the Act, so an issuer confirms current figures with the FSA before choosing between the bank, funds transfer and trust models.

Brazil: central bank rules for stablecoin services and foreign exchange

Brazil has no separate stablecoin issuer licence. Banco Central do Brasil (BCB) regulates stablecoins through the virtual asset service providers that offer them, under three resolutions of 10 November 2025: Resolution BCB 519 on authorisation, Resolution BCB 520 on how these firms operate and Resolution BCB 521 on foreign exchange. Resolution 520 and most of Resolution 521 have applied since 2 February 2026.

Resolution 520 defines a stablecoin as a virtual asset backed by reserve assets to keep its value tied to a fiat currency, and defines reserve assets as that currency and bonds of the government that issues it. Before listing one, a provider assesses the issuer's reserves, proof of reserves and audited accounts. Resolution 521 places the purchase, sale and exchange of fiat-referenced stablecoins, international payments in virtual assets and transfers to and from self-custodied wallets in the foreign exchange market.

Kenya: Central Bank of Kenya under the VASP Act 2025

Kenya's Virtual Asset Service Providers Act 2025 (No. 20 of 2025) received assent on 15 October 2025 and came into force on 4 November 2025. It assigns stablecoin issuance, defined as creating and managing approved stablecoins, to the Central Bank of Kenya (CBK), which also licenses custodial wallets and virtual asset payment processors; exchanges, brokers and coin offerings go to the Capital Markets Authority.

The Act defines a stablecoin as a virtual asset pegged to one or more reserve assets, including currency, commodities or other virtual assets, and provides for regulations on the issuance and use of stablecoins. The National Treasury consulted on draft regulations until 10 April 2026. Capital, reserve and redemption standards sit in those regulations, which applicants confirm with the CBK before filing.

Australia: payments licensing reform to watch

On 9 October 2025 the Australian Treasury released exposure draft legislation for a payments licensing regime with a graduated framework for stored value facilities that names stablecoin issuers, and a further tranche to cover safeguarding and APRA supervisory powers. Issuers confirm the final law and its start date before committing there.

Choosing where to issue and how to serve several markets

Only the EU passport spans several countries; elsewhere each market wants its own entity, reserve accounts and approval. The first licence follows the currency, the customers and where the reserves sit.

Build the reserve once, to the strictest common standard

A reserve of bank deposits and government bills with 90 days or less to run meets the asset lists in the US (93 days), Canada (three months) and Dubai (90 days); the UAE central bank wants cash in escrow, and an EU e-money token keeps at least 30% in bank deposits. A redemption process that pays within one business day meets the UK, Hong Kong and UAE standards and clears Canada's three days and Singapore's five.

The legal holding of the reserve cannot be shared. Canada requires a Canadian-incorporated custodian, the UAE central bank a UAE bank outside the group, Hong Kong a trust arrangement per coin and the UK a statutory trust with at most 20% at group custodians. A foreign issuer serving US customers holds enough reserves in US institutions to meet US redemptions, and Singapore proposes the stricter of its rules and the other regulator's for reserves shared across jurisdictions. Each entity holds its own reserve, reconciled daily against the coins it has issued.

Who may issue decides the group structure

Singapore and the UAE central bank send banks through a separate company and Canada's Act excludes financial institutions, so a bank group uses a dedicated issuing subsidiary; a fintech group uses an EMI in the EU and a direct issuer licence elsewhere.

Distribution needs its own permissions

The issuer licence covers minting, redemption and the reserve. Platforms that sell or hold the coin need their own permissions: MiCA CASP authorisation in the EU, money transmission licences in the US, FCA crypto permissions in the UK, digital payment token licences in Singapore and VARA licences in Dubai.

Sequencing

The UK window closes on 28 February 2027, so a firm that wants a UK coin at the start files now. US issuers build the OCC file to the final rule now. Canada and Singapore follow once their rules are final, reusing the reserve and governance documents already prepared.

Stablecoin regulation timeline: the next 12 months

After that, US state regulators certify their regimes by 18 January 2028, and the US limit on distributing non-permitted coins applies from 18 July 2028. MAS has not yet announced when the Singapore amendments will be made.

How Buckingham Capital Consulting supports stablecoin issuers

• Market choice: the first licence, and the group structure for issuance, custody and distribution.
• Applications: FCA, EMI and MiCA, OCC and state, HKMA, MAS, CBUAE and VARA filings, managed through review.
• Reserves and redemption: reserve policy, trust and custody arrangements, reconciliation and monthly reporting.

Frequently asked questions

References

1. FCA PS26/10: Crypto regime, stablecoin issuance (June 2026)
2. FCA PS26/12: A prudential regime for cryptoasset firms (June 2026)
3. Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA), EUR-Lex
4. EBA: The EBA classifies USDC as the first significant e-money token in the European Union (14 October 2026)
5. ESMA: supervisory expectations on services related to unauthorised stablecoins (8 October 2026)
6. GENIUS Act, Public Law 119-27 (GovInfo)
7. OCC Bulletin 2026-50: GENIUS Act regulations, final rule (21 October 2026)
8. Canada Gazette, Part I, Vol. 160, No. 43: Stablecoin Regulations (24 October 2026)
9. MAS consultation P015-2026: amendments to the Payment Services Act 2019 for stablecoin regulation
10. HKMA: Explanatory Note on Licensing of Stablecoin Issuers (July 2025)
11. CBUAE Rulebook: Payment Token Services Regulation
12. Banco Central do Brasil: Resolução BCB nº 521 (10 November 2025)

Speak to an expert: WhatsApp +44 7563 115980, Telegram @buckinghamcapital or [email protected].

This article is general information, not legal advice. Requirements change, and the regulator’s own publications take precedence.