Eight regimes, none of them matching

GENIUS Act missed its own deadline

Chapter 1 defined a payment stablecoin as a US statutory category: a digital asset meant for payment or settlement whose issuer is obliged to redeem it at a stated monetary value. The Guiding and Establishing National Innovation for U.S. Stablecoins Act, signed 18 July 2025 as Public Law 119-27, is that statute. It excludes central-bank currency, bank deposits (including deposits on a distributed ledger), and securities. The definition has no word for blockchain and no word for reserve. It is an issuer's redemption duty.

Three kinds of firm may issue. A subsidiary of a bank insured by the FDIC or NCUA. A nonbank approved federally by the Office of the Comptroller of the Currency. A state-qualified issuer, but only up to 10 bn USD of issuance, counted as a 30-day rolling average. Cross the threshold and the issuer has 360 days to move under federal supervision or must stop minting new tokens. Non-financial public companies need unanimous consent from the Stablecoin Certification Review Committee, a barrier aimed at names such as Meta, Amazon or X.

Two market-shaping prohibitions sit next to that gate. The issuer may not pay yield to holders. Eligible reserves are a closed list: cash and Federal Reserve balances, deposits at insured banks, Treasury bills of 93 days or less, repurchase agreements backed by those bills, government money-market funds, and other assets a regulator later approves. Commercial paper, equities, gold and cryptoassets are out. Rehypothecation is barred except in narrow cases. Holders have a super-priority claim on the reserves if the issuer fails. Monthly PCAOB attestations apply to every permitted issuer; a full annual GAAP audit applies above 50 bn USD in circulation. On the 4 September 2026 DefiLlama reading used in this series, only USDT at 183.34 bn USD and USDC at 74.46 bn USD clear that line.

The statute also pulls issuers into the Bank Secrecy Act. The Bank Secrecy Act, in this setting, is the US anti-money-laundering statute that treats a permitted payment-stablecoin issuer as a financial institution, with a mandatory AML and sanctions program. That is a different posture from Tether's pre-statute claim that it was not a "US person." OFAC designation still reaches the token at the issuer. On 9 August 2022 OFAC designated 53 Ethereum addresses tied to Tornado Cash; Circle and the Centre consortium froze about 75,000 USD of USDC tied to them. That freeze is the documented early test of issuer-level sanctions compliance, three years before GENIUS Act was signed.

None of this is yet a finished federal rulebook. The one-year statutory deadline for implementing regulations was 18 July 2026. OCC, FDIC, Treasury, the Federal Reserve and NCUA issued zero final rules by that date. OCC proposed on 25 February 2026 (Comptroller Jonathan V. Gould said on 19 August 2026 a final would be out by November). FDIC proposed on 10 April 2026. Treasury proposed "substantially similar" state-regime principles on 3 April 2026 and again on 18 August 2026. The Federal Reserve, as of a 3 September 2026 tracker, had not published an NPRM for state-member-bank subsidiaries. NCUA ran two proposed-rule cycles in February and May 2026. FinCEN opened a joint customer-identification proposal on 18 June 2026. No state regime had been certified as substantially similar.

The Act takes effect on the earlier of two dates: 120 days after the primary regulators issue final implementing regulations, or 18 January 2027. Because no primary regulator had issued a final rule in time to beat the backstop, the effective date defaults to 18 January 2027. The Polish research edition also records a three-year transition for exchanges and custodians to 18 July 2028, via Greenberg Traurig; the research log found that date only in a lower-tier secondary source.

Institutions have not waited. On 12 December 2025 the OCC conditionally approved five national trust-bank charters, including Circle and Ripple as de novo banks and conversions for BitGo, Fidelity Digital Assets and Paxos. The Polish edition dates Circle's final approval for Circle National Trust to 10 July 2026. The research log confirmed the December 2025 conditional batch and Circle's later full approval, without independently pinning that July date. The pattern is the same either way: the statute is signed, the finals are late, and the large issuers are already standing under the charter window.

MiCA pushed Tether off licensed venues

Markets in Crypto-Assets applied its e-money-token and asset-referenced-token rules from 30 June 2024, and its crypto-asset service-provider rules from 30 December 2024, fourteen months before GENIUS Act was signed. An e-money token, or EMT, is a crypto-asset that references a single fiat currency and, under MiCA, may be issued only by a credit institution or a licensed electronic-money institution. An asset-referenced token, or ART, references a basket or another value. Across the sources checked in September 2026, authorised ART issuers were zero.

The reserve rule is the split with the United States. MiCA Article 54 requires at least 30% of a non-significant EMT reserve, and 60% of a significant EMT reserve, to sit as deposits at EU commercial banks. GENIUS Act points the other way: bills, cash and repo, not a mandated bank-deposit floor. Two answers to the same question, who is funded by the reserve, the US Treasury or the European banking system.

Tether has not sought EMT authorisation and says it will not, objecting to the 60% EU-bank-deposit rule. In April 2026 it called MiCA's reserve mandates incompatible with USDT's scale. USDT is absent from the EMT register readings used here. The market consequence arrived in stages, not as one order: Coinbase announced removal for European users on 3 December 2024, effective 31 March 2025; Crypto.com removed USDT effective 31 January 2025; Binance restricted EEA spot pairs in March 2025. By the 1 July 2026 CASP grandfathering deadline, no MiCA-licensed EEA exchange in this record still offered USDT trading pairs. Holding USDT in self-custody remains legal. No relisting on a major EU-facing exchange was found.

Issuer counts disagree, and they stay disagreed. A synthesis of ESMA's EMT white-paper register as of 8 August 2026 lists 22 issuers and 42 notified white papers. An unofficial aggregator updated 7 September 2026 lists 23 authorised EMT issuers, including Circle, Paxos EU and Société Générale-FORGE. A 16 July 2026 reading, published 23 July, had 21. CASP totals also conflict: 294 register entries as of 16 July 2026 after a batch of 14, against a weaker "over 40 fully authorised" claim that could not be tied to one checkable URL. Circle obtained a French electronic-money-institution authorisation in July 2024, the first global issuer the Polish edition records as MiCA-compliant.

MiCA was first. Before the 1 July 2026 deadline the Polish edition records only 244 MiCA licences issued across the whole Union, and several firms choosing to build from jurisdictions such as Dubai instead.

The EU's DLT Pilot Regime is a separate track, not a stablecoin licence. ESMA's own 25 June 2025 review found three authorised infrastructures: CSD Prague, 21X AG and 360X AG, with minimal live trading. A weakly sourced claim of six authorised DLT market infrastructures is not used here.

Six other clocks, none of them the same

The remaining six regimes do not share a phase, a reserve philosophy, or a live-versus-published status. No two rows in the matrix match.

The United Kingdom published final rules. They are not yet law in force. FCA Policy Statement PS26/10 is dated 30 June 2026, covering UK-issued qualifying stablecoins after CP25/14 and CP25/41. Issuers must fully back tokens from the point of minting, including tokens they hold themselves. Holders have a right to redeem at par, generally by the end of the business day after the token arrives in the issuer's wallet, with the clock starting after AML and KYC checks. Issuers cannot pay interest or other yield from backing assets to holders; third parties are similarly restricted from passing those payments on; non-yield rewards remain permissible. A savings-provisions application window runs from 30 September 2026 to 28 February 2027. The full statutory cryptoasset regime, including stablecoin capital rules, takes effect on 25 October 2027. On 4 September 2026, in the Polish edition's reading, no issuer including USDC or USDT used in the UK had been designated systemic.

Singapore's status is a contradiction, recorded as a contradiction. A 1 September 2026 MAS consultation on legislative amendments to the Payment Services Act 2019 indicates the Single-Currency Stablecoin framework was still pending legislative implementation. A separate source claims the framework "went live" on 1 July 2026. No named licensed issuer was found under either account. Proposed rules, where described, include 100% high-quality liquid assets, redemption at par, capital requirements, stress testing, recovery and wind-down plans, and a ban on paying interest on MAS-regulated stablecoins.

Hong Kong's Stablecoins Ordinance took effect on 1 August 2025. HKMA received 36 formal applications by 30 September 2025 and granted its first two licences on 10 April 2026, to Anchorpoint Financial Limited, a joint venture of Standard Chartered Bank (Hong Kong), HKT and Animoca Brands, and to The Hongkong and Shanghai Banking Corporation Limited. That is a 5.6% acceptance rate. Foreign entities must set up Hong Kong subsidiaries. Full backing, redemption at par within one business day after onboarding, and minimum paid-up capital of 25 million Hong Kong dollars (unless the applicant is already an authorized institution) are the named bars. Further grants were described as still under assessment in April 2026; no further named licences were found by September.

Japan revised its Payment Services Act in June 2023, treating fiat-backed tokens as electronic payment instruments issuable by banks, funds-transfer providers and trust companies. JPYC launched on 27 October 2025. A later reform allows up to 50% of reserves in short-term Japanese government bonds. The yen segment is below 0.01% of global supply in the Polish edition's mid-2026 reading.

Switzerland has no dedicated issuer licence yet. Current issuers rely on a full banking licence or the 2018 FinTech licence plus a bank guarantee under FINMA Guidance 06/2024, published 26 July 2024. A FinIA consultation from 22 October 2025 to 6 February 2026 proposed a payment-institution category for value-stable crypto-based payment instruments, expected "late 2026 or early 2027." As of 10 September 2026 that licence is not in force.

The United Arab Emirates is three disagreeing accounts of the same Payment Token Services Regulation, none confirmable against CBUAE's own Rulebook, which returned HTTP 403 on every fetch in the research pass. Version A: Circular No. 2/2024 (June 2024) plus a one-year transition. Version B: Federal Decree-Law No. 6 of 2025 dated 8 September 2025, transition running to 16 September 2026. Version C: the transitional period "officially ended in June 2025." Algorithmic stablecoins are banned. Dirham Payment Token issuers must be UAE-incorporated, excluding the financial free zones. Non-UAE issuers may apply as Foreign Payment Token issuers. AE Coin was licensed in December 2024 as a dirham token. Named licensed issuers under Dubai's VARA or Abu Dhabi's ADGM/FSRA frameworks were not found.

An issuance licence is not a payment licence

Stablecoin statutes answer what the token is. They do not, by themselves, answer what a firm may do with a customer's dollars before a token is minted or after it is redeemed.

An issuance licence is the permission to mint a token and to hold the matching reserve. GENIUS Act's permitted-issuer tracks, MiCA's EMI or bank authorisation, and Hong Kong's Stablecoins Ordinance licences are this layer. A payment licence is the permission to receive, hold or transfer customer money: a banking licence, an electronic-money institution, a payment institution, a US money-transmitter licence, access to clearing. A firm can hold a compliant EMT and still have no right to take a euro deposit from a customer, because it lacks the payment authorisation.

The payment layer is usually the harder and earlier barrier. One EMI passport covers 27 EU countries. The same business in the United States is licensed state by state. Bridge, now inside Stripe, holds 33 US money-transmitter licences and one Luxembourg EMI-plus-CASP covering the Union, in the Polish edition's licence map. Circle pairs an OCC national trust charter (final approval dated 10 July 2026 in that edition) with a French EMI and CASP from 1 July 2024.

Hong Kong's 2-of-36 acceptance rate is the issuance-layer version of the same sieve. The payment layer sieves earlier. Mint and burn can be copied in weeks. Thirty-three money-transmitter licences, or a single EMI that lets the firm accept customer funds, take months to years.

Issuers register where the cost is lowest

Three jurisdiction strategies are visible. None of them is "go where the rulebook is strictest."

Tether moved its corporate base from the British Virgin Islands to El Salvador in January 2025, after a Digital Asset Service Provider licence. Bloomberg dated the move 13 January 2025. El Salvador's Digital Assets Issuance Law is 2023; CNAD had licensed more than 70 digital-asset service providers in the Polish edition's May 2026 reading. Bitfinex, Tether's sister, received its own DASP licence on 12 May 2026. The trade is a Bitcoin-friendly jurisdiction without a MiCA-style deposit floor, at the cost of licensed EEA venue access. In parallel Tether announced USAT, US-domiciled, issued by Anchorage Digital Bank, aimed at GENIUS Act. Dual track, not full compliance with one regime.

Circle collected licences instead of relocating the flagship token. NYDFS BitLicense in 2015, first global MiCA-compliant issuer in 2024, licences in the UK, Singapore and Bermuda, Canadian value-referenced crypto-asset compliance in the Polish edition's July 2026 reading, and the OCC national trust charter in 2026. Costly to run. The MiCA delisting that hit USDT is the event this stack is built not to repeat.

The third path is a local bank partner. Anchorpoint and HSBC in Hong Kong are the type case: two licences from 36 applications, both bank-linked, granted 10 April 2026.

El Salvador's register of more than 70 licensed firms, set against 244 MiCA licences for the whole EU before 1 July 2026, is the uncomfortable arithmetic. The jurisdiction without comparable banking supervision currently hosts the largest token.

The yield-ban column on the matrix is the most divergent of the seven. GENIUS Act and the UK rules bar the issuer from paying holders. MiCA has no US-style general ban. Hong Kong, Japan and Switzerland are unresolved here. Wrapper tokens, named in chapter 1, sit beside that gap.

Treasury had not, as of the sources here, published the criteria under which a foreign issuer's regime is "comparable" for GENIUS Act purposes. The foreign-permitted-issuer restriction can arrive before a legal path exists for a compliant offshore firm to walk through it.