The Bank for International Settlements’ Financial Stability Institute published FSI Briefs No. 33 in August 2026, comparing stablecoin issuer rules across the European Union, Hong Kong, Singapore, the United Kingdom and the United States under the GENIUS Act. Its main point is straightforward: jurisdictions are bringing stablecoins into regulation, but the same term, “stablecoin issuer,” carries very different permissions and limits depending on where the issuer operates. In most cases, the restrictions apply to the issuing entity, not the wider group.
Market size has flattened at about $300 billion to $320 billion
The report starts with market structure. Total stablecoin market capitalization has shifted from rapid growth to a flatter pattern, holding at roughly $300 billion to $320 billion since October 2025. BIS said that still represents only about 7% of the broader crypto market.
The market remains highly concentrated. Two issuers account for about 90% of total stablecoin capitalization: Tether’s USDT and Circle’s USDC.
The brief focuses on money-like payment stablecoins, meaning tokens pegged 1:1 to fiat currency and marketed around redemption at par value.
Issuance rules differ for banks, non-banks and foreign entities
Whether an entity can issue a stablecoin depends on the local framework. BIS said banks and non-banks follow different paths.
For bank issuers, banks in the European Union only need to notify the competent authority. In Hong Kong, the UK and the US, banks need a stablecoin-specific license, and both the UK and the US require issuance through a subsidiary.
For non-bank issuers, a payments license is enough in the European Union and Singapore. Hong Kong, the UK and the US require a dedicated stablecoin authorization.
Cross-border issuance rules are tighter, with Hong Kong listed as the only exception
The report says most jurisdictions do not allow foreign-incorporated issuers to issue directly in the local market. Hong Kong is the only exception in the five-way comparison. It allows a foreign “recognized institution,” meaning a bank, to issue through a Hong Kong branch after obtaining a license from the Hong Kong Monetary Authority.
The United States has a transition period. After July 2028, foreign stablecoins may only be issued by licensed entities from “designated countries,” and those entities must register with and be supervised by the Office of the Comptroller of the Currency, or OCC.
Large “systemic” stablecoins also face extra layers of oversight. In the European Union, the European Banking Authority, or EBA, determines whether a stablecoin is “significant.” In the UK, the Treasury designates a coin as “systemic,” after which supervision moves to the Bank of England. In the US, the threshold is circulation above $10 billion, with a requirement to move into federal supervision within 360 days, subject to exemption.
Reserve custody, redemption fees and redemption timing split the five regimes
On core activities such as issuance, reserve management and redemption, the five jurisdictions follow a similar broad direction but diverge in the details.
The clearest split is whether reserves can be self-custodied. The European Union and the United States allow it, subject to segregation requirements. Singapore does not allow it. The UK places a 20% cap on intragroup custody.
Redemption fees also vary. Hong Kong, the UK and the US allow reasonable fees. The European Union bars redemption fees except during stress events, aiming to preserve redemption at par.
Redemption timelines are not aligned either. Singapore allows up to five business days. The US proposal sets two business days. Hong Kong requires redemption by the next business day. The European Union requires redemption “at any time.”
There is one point of full alignment across all five jurisdictions: issuers cannot pay interest to holders. BIS presents that as a shared policy choice to keep payment stablecoins separate from yield-bearing investment products. The Financial Conduct Authority’s final crypto rules in the UK take the same position.
Non-core activities fall into two regulatory models
The report says the biggest practical differences appear in activities outside the core stablecoin business, including lending, staking, proprietary trading and custody of crypto assets for third parties.
BIS groups the approaches into two models:
- A restrictive model, which confines issuers to a narrow activity set. Singapore does this through explicit prohibitions, while the US GENIUS Act uses a positive list approach, meaning activities not listed are not allowed.
- A constrained model, which does not ban diversification outright but requires a separate authorization or compliance with the relevant sectoral rules for each additional activity. Hong Kong, the UK and the European Union fall into this category.
For bank issuers, BIS said these restrictions are often displaced by existing prudential banking rules, which means the banking framework effectively takes over.
BIS flags a gap at the group level for non-bank issuers
The strongest warning in the brief is that these restrictions generally bind the issuing entity itself rather than the entire corporate group.
For bank issuers, BIS said the gap is partly addressed through consolidated supervision and limits on intragroup exposures. For non-bank issuers, there is no equivalent group-level framework. That leaves room to work around restrictions by moving prohibited activities to sister companies within the same group.
The report says stablecoin frameworks, or related prudential rules, may need to extend to the group level for non-bank issuers, especially where larger groups are involved.
Cross-border circulation and concentration make arbitrage harder to police
BIS ends with a broader warning. Stablecoins can move across borders freely, and the market is concentrated in a small number of issuers. In the report’s view, that combination increases the difficulty of regulatory arbitrage and cross-border supervision.
For that reason, BIS said effective stablecoin oversight will depend on cooperation between national regulators and alignment with international standard-setting bodies. For policymakers still drafting or implementing stablecoin rules, the comparison offers a direct side-by-side reference and a clear picture of where the next regulatory gap sits.