グローバル・ステーブルコイン規制 五極比較マトリクス（US / EU / 日本 / HK / SG）
ConfidenceConfirmedUpdated2026-07-30Review by2026-10-30Sources6Machine-translatedOriginal (JA)
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Wiki route
This entry sits under fintech index and compares five major public regulatory frameworks at a common level of abstraction. It complements US/EU/Japan stablecoin market-access comparison, but it does not assume that any bilateral recognition arrangement exists unless an official source is cited. For per-regime context, see MiCA, Japan, Hong Kong, and Singapore.
[!info] TL;DR The five frameworks share a policy direction—identifiable issuers, reserve and redemption safeguards, governance, and AML/CFT controls—but they are not five interchangeable passports. Their legal status and scope differ: US GENIUS implementation remains tied to its statutory effective-date and rulemaking triggers; EU MiCA’s ART and EMT titles have applied since June 30, 2024; Japan’s electronic-payment-instrument regime began June 1, 2023; Hong Kong’s Stablecoins Ordinance took effect August 1, 2025 and the first two licences were announced in April 2026; Singapore’s 2023 SCS framework defines the conditions for the “MAS-regulated stablecoin” label. ^[https://www.govinfo.gov/app/details/PLAW-119publ27] ^[https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1114] ^[https://www.fsa.go.jp/policy/virtual_currency02/index.html] ^[https://www.hkma.gov.hk/media/eng/publication-and-research/annual-report/2025/16_International_Financial_Centre.pdf] ^[https://www.mas.gov.sg/news/media-releases/2023/mas-finalises-stablecoin-regulatory-framework]
How to read the matrix
This is a dated legal map as of July 30, 2026, not legal advice. “Framework” does not always mean that an identical standalone licence category is live in every jurisdiction. A token’s treatment depends on issuer, denomination, place of issuance, marketing, distribution, and the services performed around it.
Matrix A · Legal basis, regulator, and status
Because the dates and transition rules come from different legal instruments, each row carries its own official marker.
| Pole | Legal basis and lead authority | Confirmed status as of 2026-07-30 | Source |
|---|---|---|---|
| 🇺🇸 US | GENIUS Act, Public Law 119-27; federal and qualifying state regulators | Enacted 2025-07-18. Effective on the earlier of 18 months after enactment or 120 days after qualifying final regulations | ^[https://www.govinfo.gov/app/details/PLAW-119publ27] |
| 🇪🇺 EU | Regulation (EU) 2023/1114; national competent authorities, EBA and ESMA within assigned roles | ART and EMT titles apply from 2024-06-30; most remaining MiCA provisions from 2024-12-30 | ^[https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1114] |
| 🇯🇵 Japan | Payment Services Act and Banking Act framework; FSA and relevant registration authorities | Electronic payment instrument intermediary / handling regime began 2023-06-01; a 2026 amendment package took effect 2026-06-01 | ^[https://www.fsa.go.jp/policy/virtual_currency02/index.html] |
| 🇭🇰 Hong Kong | Stablecoins Ordinance (Cap. 656); HKMA | Regime effective 2025-08-01; first batch of two licensed issuers announced in 2026-04 | ^[https://www.hkma.gov.hk/media/eng/publication-and-research/annual-report/2025/16_International_Financial_Centre.pdf] |
| 🇸🇬 Singapore | Payment Services Act context and MAS SCS regulatory framework; MAS | MAS finalised the SCS framework in 2023-08; compliant issuers may use the “MAS-regulated stablecoin” label | ^[https://www.mas.gov.sg/news/media-releases/2023/mas-finalises-stablecoin-regulatory-framework] |
The prior version’s blanket “18-month grandfathering ended July 2026” statement confused MiCA’s CASP transition in Article 143 with ART/EMT treatment. It also reported Hong Kong’s first licences one month late and treated the US statute as operational from signature. Those claims are corrected above.
Matrix B · Regulated object and issuer path
The table is based on the enacted US law, MiCA’s ART/EMT titles, Japan FSA’s electronic-payment-instrument page, HKMA’s issuer regime, and MAS’s SCS announcement. ^[https://www.govinfo.gov/content/pkg/PLAW-119publ27/pdf/PLAW-119publ27.pdf] ^[https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1114] ^[https://www.fsa.go.jp/policy/virtual_currency02/index.html] ^[https://www.hkma.gov.hk/eng/key-functions/international-financial-centre/stablecoin-issuers/] ^[https://www.mas.gov.sg/news/media-releases/2023/mas-finalises-stablecoin-regulatory-framework]
| Pole | Regulated object | Issuer / authorization path at a high level |
|---|---|---|
| US | Payment stablecoin as defined in Public Law 119-27 | Permitted issuer may be an approved subsidiary of an insured depository institution, a federal qualified nonbank issuer, or a state qualified issuer |
| EU | Asset-referenced token (ART) or e-money token (EMT) | EMT issuance is limited to credit institutions or electronic-money institutions; ART authorization follows Title III, with a credit-institution route |
| Japan | Electronic payment instrument tied to fiat value; issuance and intermediary functions are legally distinct | Issuance can arise through bank, funds-transfer, or trust structures; intermediaries need the applicable registration |
| Hong Kong | Fiat-referenced stablecoin within the Ordinance’s territorial and marketing scope | Issuance subject to an HKMA stablecoin-issuer licence; an existing financial licence does not by itself answer Stablecoins Ordinance compliance |
| Singapore | Single-currency stablecoin issued in Singapore and pegged to SGD or a G10 currency within the MAS framework | Issuer must meet the SCS framework to use the MAS-regulated label; other tokens remain subject to the otherwise applicable regime |
“Algorithmic stablecoin ban” is not used as a universal matrix field here. The five frameworks define covered products and impose reserve or redemption conditions in different ways. A design may fall outside a regulated stablecoin category without every jurisdiction using the same statutory prohibition.
Matrix C · Reserve, redemption, and disclosure
These rows deliberately avoid invented universal capital floors or attestation cadences. The source instruments support the following high-level comparison. ^[https://www.govinfo.gov/content/pkg/PLAW-119publ27/pdf/PLAW-119publ27.pdf] ^[https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1114] ^[https://www.hkma.gov.hk/eng/key-functions/international-financial-centre/stablecoin-issuers/] ^[https://www.mas.gov.sg/news/media-releases/2023/mas-finalises-stablecoin-regulatory-framework]
| Pole | Reserve / safeguarding direction | Redemption and disclosure direction |
|---|---|---|
| US | At least 1:1 identifiable reserves limited to statutory asset classes; segregation and risk-management rules | Timely redemption under disclosed policy; monthly reserve reporting examined by a registered public accounting firm |
| EU | ART reserve-of-assets requirements; EMTs are treated as electronic money and subject to the relevant MiCA and e-money rules | Redemption rights and issuer disclosures depend on ART versus EMT classification |
| Japan | Safeguarding follows the legal form of the issuer or trust and the electronic-payment-instrument rules | Do not infer a single reserve asset list or transaction ceiling across all three issuer forms |
| Hong Kong | Full backing with reserve-asset management, segregation, and risk controls under the Ordinance and supervisory guideline | Par redemption and public disclosure are core licensing requirements; exact operational controls are assessed in licensing and supervision |
| Singapore | Low-risk, highly liquid reserve assets in the peg currency, held in segregated custody | Par redemption within the framework’s stated period, disclosure, audit, and capital / liquid-asset safeguards |
The previous table’s OCC “$50M floor,” Japan “¥100M trust minimum,” Hong Kong “2% ongoing capital,” and claims of daily public attestation were not supported by the cited sources and have been removed.
Matrix D · Cross-border access
The table records confirmed legal entry points without asserting any unsigned mutual-recognition agreement. ^[https://www.govinfo.gov/content/pkg/PLAW-119publ27/pdf/PLAW-119publ27.pdf] ^[https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1114] ^[https://www.fsa.go.jp/policy/virtual_currency02/index.html] ^[https://www.hkma.gov.hk/eng/key-functions/international-financial-centre/stablecoin-issuers/] ^[https://www.mas.gov.sg/news/media-releases/2023/mas-finalises-stablecoin-regulatory-framework]
| Pole | Confirmed cross-border boundary |
|---|---|
| US | Section 18 provides a process for Treasury determinations and arrangements involving comparable foreign regimes; a specific bilateral arrangement must be verified from its official publication |
| EU | Third-country issuance or service provision does not acquire an automatic MiCA passport; entity, offer, admission-to-trading, and service facts matter |
| Japan | Foreign-issued instruments may require a registered domestic intermediary and product-specific review; distributor status is distinct from issuer status |
| Hong Kong | The Ordinance covers issuance in Hong Kong, issuance outside Hong Kong of an HKD-referenced stablecoin, and active marketing of issuance business to the Hong Kong public |
| Singapore | The SCS label framework is for qualifying SGD or G10-pegged SCS issued in Singapore; overseas issuance is not automatically MAS-regulated |
The earlier assertions that a US–Japan MRA was signed in February 2026 and an EU agreement was expected in 2026-Q3 had no cited official instrument and are withdrawn.
Matrix E · AML/CFT and supervision
The table is sourced to each regime’s primary framework; it describes direction rather than pretending that reporting forms and resolution processes are identical. ^[https://www.govinfo.gov/content/pkg/PLAW-119publ27/pdf/PLAW-119publ27.pdf] ^[https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1114] ^[https://www.fsa.go.jp/policy/virtual_currency02/index.html] ^[https://www.hkma.gov.hk/eng/key-functions/international-financial-centre/stablecoin-issuers/] ^[https://www.mas.gov.sg/news/media-releases/2023/mas-finalises-stablecoin-regulatory-framework]
| Pole | Confirmed supervisory direction |
|---|---|
| US | Permitted issuers are treated as financial institutions for BSA and sanctions purposes; primary regulator depends on issuer path |
| EU | MiCA authorization and ongoing supervision operate alongside EU AML/CFT and transfer-of-funds requirements |
| Japan | Issuer and intermediary roles map to different statutes, registration, safeguarding, and AML/CFT obligations |
| Hong Kong | HKMA licensing, prudential supervision, reserve management, redemption, governance, and a dedicated AML/CFT guideline |
| Singapore | MAS framework covers value stability, capital, redemption, disclosure, and business restrictions; other PSA obligations continue to depend on activities |
There is no sound basis for the previous claims that every framework mandates monthly third-party attestation, that MAS requires daily public disclosure, or that bank-resolution statutes apply to all issuers in the same way.
Practical routing questions
Instead of selecting a jurisdiction from a single capital number, counsel and treasury teams should ask:
- Who legally issues the token, and where?
- What currency or asset does it reference?
- Who offers, markets, distributes, exchanges, or safeguards it in each market?
- Which rules are already effective, and which remain proposed or transitional?
- Does an asserted passport, equivalence decision, or bilateral arrangement have an official instrument and effective date?
- Do reserve, redemption, governance, and AML controls cover every issuance network and distributor?
The answers may require separate issuer and distributor entities. That is a compliance architecture decision, not evidence of a time-limited “regulatory arbitrage window.”
Related
- Wiki Index
- Fintech Index
- US/EU/Japan stablecoin market-access comparison
- EU MiCA · Markets in Crypto-Assets Regulation Overview
- Three-Layer Structure of Japan's Stablecoin Regulatory Regime (JPYC, USDC, Project Pax)
- Japan's three EPI issuance routes · overview of trust, bank and funds-transfer-provider models
- HKMA Stablecoin Licensing · Hong Kong Stablecoin Licensing Regime Overview
- Singapore MAS Payment Services Act + SCS Framework Overview
- Exchanges
Sources
- US · Public Law 119-27: https://www.govinfo.gov/app/details/PLAW-119publ27
- EU · Regulation (EU) 2023/1114: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1114
- Japan FSA · crypto-assets and electronic payment instruments: https://www.fsa.go.jp/policy/virtual_currency02/index.html
- Hong Kong HKMA · stablecoin issuers: https://www.hkma.gov.hk/eng/key-functions/international-financial-centre/stablecoin-issuers/
- Hong Kong HKMA · 2025 annual report, International Financial Centre: https://www.hkma.gov.hk/media/eng/publication-and-research/annual-report/2025/16_International_Financial_Centre.pdf
- Singapore MAS · final SCS regulatory framework: https://www.mas.gov.sg/news/media-releases/2023/mas-finalises-stablecoin-regulatory-framework
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