Global Stablecoin Rules in Focus: A Cross-Border Guide to the New Era of Stablecoin Regulation
Client Alert | March 13, 2026
Stablecoins have moved from experimental rails to core market infrastructure, prompting regulators around the world to define who may issue them, how reserves must be held, and what rights users have upon redemption, among other things.
Across leading jurisdictions, common policy aims—payment stability and consumer protection—coexist with divergent approaches to licensing, prudential standards, disclosures, custody, and market conduct.
The United States is progressing through a patchwork of federal and state measures, but with the adoption of the GENIUS Act, there is increasing comfort that the U.S. will implement a clear regulatory framework. The European Union has adopted a comprehensive, passportable regime for cryptoassets and connected services. The United Kingdom is bringing crypto-assets, including stablecoins, within its regulatory framework. Hong Kong recently implemented a licensing regime for fiat-referenced stablecoin issuers. Singapore is finalizing a stablecoin framework emphasizing reserve quality, par-value redemption and disclosures. The United Arab Emirates supervises issuance, custody, and marketing through a mix of federal oversight and financial free-zone regimes. Other markets—from Japan and Switzerland to Canada, Australia, and Brazil—are likewise codifying rules that vary in scope, timing, and supervisory style.
For issuers, distributors, exchanges, and institutional users, regulatory differences across jurisdictions drive concrete choices, including where to domicile an issuing entity, how to structure reserves and attestations, product design, redemption procedures, listing and distribution strategies, contractual terms with partners, and contingency planning for stress events. Although the regulatory landscape continues to rapidly evolve, the sections that follow provide a snapshot view of the current United States, European Union, United Kingdom, Hong Kong, Singapore and UAE frameworks, and identify the operational implications for market participants.
A chart comparing the current regulatory regimes is provided in Appendix 1.
For ease of reference, a glossary of defined terms is available in Appendix 2.
Please view Gibson Dunn’s complete Cross-Border Guide at the following link:
Gibson Dunn’s lawyers are available to assist with any questions you may have regarding these developments.
To learn more, please contact the Gibson Dunn lawyer with whom you usually work, the authors, or any leader or member of the firm’s Financial Institutions, Fintech & Digital Assets, or Financial Regulatory practice groups:
Ro Spaziani – New York (+1 212.351.6255, rspaziani@gibsondunn.com)
Jason J. Cabral – New York (+1 212.351.6267, jcabral@gibsondunn.com)
Hagen H. Rooke – Singapore (+65 6507 3620, hhrooke@gibsondunn.com)
Michelle M. Kirschner – London (+44 20 7071 4212, mkirschner@gibsondunn.com)
Sameera Kimatrai – Dubai (+971 4 318 4616, skimatrai@gibsondunn.com)
William R. Hallatt – Hong Kong (+852 2214 3836, whallatt@gibsondunn.com)
Jeffrey L. Steiner – Washington, D.C. (+1 202.887.3632, jsteiner@gibsondunn.com)
Sara K. Weed – Washington, D.C. (+1 202.955.8507, sweed@gibsondunn.com)
Emily Rumble – Hong Kong (+852 2214 3839, erumble@gibsondunn.com)
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