Stablecoins are no longer a niche crypto primitive. They are increasingly used for payments, treasury management, settlement, and cross-border value transfer – and, as a result, they are rapidly becoming part of the regulated financial system.

Over the past two years, regulators across major jurisdictions have moved decisively from principles and consultations to formal legal frameworks for stablecoins. But this progress has not been uniform. Different regions are taking very different approaches to what a stablecoin is, who may issue one, how it must be backed, and how it should be supervised.

For institutions operating across borders – or even evaluating whether and where to launch a stablecoin – understanding these differences is now essential.

To help make sense of this landscape, we’re launching the Cryptio Stablecoin Regulation Map: an interactive, region-by-region view of how stablecoins are regulated across the world’s most significant markets.

The challenge: stablecoin regulation is fragmented – and hard to compare

There is no single global model for stablecoin regulation.

Some jurisdictions have introduced bespoke, category-based regimes. Others are regulating stablecoins through existing banking, payments, or trust law. In several markets, multiple issuance pathways coexist in parallel – each with different implications for reserves, reporting, custody, and insolvency treatment.

As a result, answering seemingly simple questions often requires stitching together multiple sources:

• Can a non-bank issue a stablecoin in this jurisdiction?
• What assets can be used as reserves – and how liquid must they be?
• Are reserves segregated, safeguarded, or bankruptcy-remote?
• What reporting, attestation, or reconciliation is required?
• When do proposed rules actually come into force?

These details matter operationally. They determine how a stablecoin is structured, how it is accounted for, how it is audited, and how it can be offered across borders.

A practical reference: the Stablecoin Regulation Map

The Cryptio Stablecoin Regulation Map is designed as a practical reference for institutions, issuers, and service providers.

Rather than offering high-level summaries, the map breaks each jurisdiction down by issuance pathway, and surfaces the information teams actually need to operate:

• legal classification and regulatory status
• who may issue (and under what licence)
• reserve and safeguarding requirements
• reporting and disclosure expectations
• reconciliation and record-keeping obligations
• custody and insolvency treatment
• Allowed stablecoin types
• notable prohibitions or design constraints

Each entry is designed to be concise, specific, and directly comparable across regions – and the map will continue to evolve as frameworks are finalised and implemented.

Three regulatory philosophies shaping stablecoins today

While every jurisdiction has its own nuances, three broad regulatory approaches are emerging across the EU, UK and US.

United States: parallel pathways and institutional choice

The United States does not have a single stablecoin regime. Instead, it offers multiple parallel issuance pathways, including:

• The GENIUS Act: a new federal framework for payment stablecoins
• OCC/banking issuance pathways under federal banking and trust law
• State-level regimes, most notably the NYDFS in New York

Each pathway carries different implications for reserve composition, disclosure, supervision, and insolvency protection. This provides flexibility – but also complexity – particularly for issuers planning to scale nationally or transition between regimes over time.

European Union: one framework, clear categories

The EU has taken a very different approach through its Markets in Crypto-Assets Regulation (MiCA).

MiCA introduces a single, harmonised framework across all Member States, with stablecoins divided into two clearly defined categories:

• E-Money Tokens (EMTs) – single-currency, fully safeguarded, redeemable at par
• Asset-Referenced Tokens (ARTs) – stablecoins referencing multiple assets or baskets, subject to stricter governance and risk controls

The result is clarity and consistency, but also a high operational bar: issuers must meet detailed requirements around reserves, safeguarding, reporting, and supervision from day one.

United Kingdom: staged regulation with a systemic overlay

The UK is taking a more staged approach.

• A forthcoming FCA-led regime will bring “qualifying stablecoins” – reserve-backed, fiat-referenced tokens used for payments – into the financial services perimeter.
• Separately, the Bank of England is developing a regime for systemic stablecoins, which would be regulated as critical payment infrastructure once designated as systemically important.

A key feature of the UK approach is the explicit distinction between reserve-backed stablecoins and deposit-based money – reflecting a clear policy choice not to treat stablecoin issuers as banks by default.

What this means in practice

Across these jurisdictions, a few themes are becoming clear:

• Issuance structure matters: the same token design may be permissible in one regime and prohibited in another.
• Reserves are no longer a design choice: their composition, custody, and segregation are increasingly prescribed.
• Reporting and reconciliation are regulatory requirements: proving 1:1 backing, tracking mint and burn activity, and supporting attestations are now expected.
• Cross-border strategies are complex: operating in multiple regions often means complying with multiple, non-equivalent regimes simultaneously.

For institutions, this shifts stablecoins from an experimental technology to a regulated financial product with real operational consequences.

Why this matters for accounting, reporting, and control

As stablecoin regulation matures, the focus is moving beyond legal authorisation to ongoing compliance and control.

Issuers and institutions must be able to:

• Reconcile on-chain supply with off-chain reserves
• Evidence segregation and safeguarding
• Support audits, attestations, and regulatory reporting
• Maintain defensible records across multiple systems

These challenges sit at the intersection of blockchain data, accounting systems, and regulatory reporting – and they are only increasing as stablecoins scale.

Explore the Stablecoin Regulation Map

The Cryptio Stablecoin Regulation Map is designed to help teams navigate this complexity – whether they are assessing new markets, designing an issuance model, or supporting regulated operations.

Explore the map here: https://stablecoin-regulation-map.cryptio.co/

We’ll continue updating it as regimes evolve, rules are finalised, and new jurisdictions come into scope.

Built with real issuers and institutions in mind

Cryptio works with the leading stablecoin issuers globally to provide independent supply side attestations and reconciliation of all mint and burn activity against internal issuer records, providing an external source of truth trusted by the Big 4.

Our clients include organisations such as Circle, Gemini, Société Générale, Paxos, Agora, and M0, alongside other banks, custodians, and regulated crypto-native firms.

Get in touch to learn how Cryptio can support attestions and reporting for your stablecoin or RWA operations.