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Regulation

How MiCAR, US initiatives, e‑CNY and other key markets define the framework for stablecoins, CBDCs and digital assets – and what this means for mid‑market corporates, compliance and ERP processes.

Regulation Topics at a Glance

MiCAR (EU)

The Fundamentals of the Crypto-Asset Regulation

Why the EU created MiCAR, which three token categories the regulation distinguishes, whom it obliges and what it expressly does not govern.

Key Points

  • Reasons, aims and timeline
  • E-money tokens, ARTs and other crypto-assets
  • Issuers, service providers, supervision and register
  • Exclusions: financial instruments, deposits, NFTs, central banks

USA – CLARITY Act & GENIUS Act

One Stablecoin Law and One Open Process

The GENIUS Act has been law since July 2025 and takes effect by January 2027 at the latest. For the CLARITY Act, the Senate vote on taking up the bill failed on 15 September 2026. What both govern and what that means for companies doing business in the US.

Key Points

  • GENIUS Act: issuers, reserves, interest ban, insolvency
  • Deadlines and issuers outside the US
  • CLARITY Act: SEC, CFTC and the status in the Senate
  • SEC and CFTC interpretation (Project Crypto)

China – e‑CNY & Crypto Regime

Digital Money via Banks, Prohibitions on the Mainland

Since January 2026, e‑CNY in a bank wallet is an interest-bearing deposit. Since February 2026, Notice No. 42 prohibits business with crypto-assets and stablecoins on the mainland. Hong Kong grants its own stablecoin licences. As of September 2026.

Key Points

  • e‑CNY: from digital cash to a deposit
  • Notice No. 42: crypto-assets, stablecoins, RWA
  • Hong Kong: Stablecoins Ordinance and first licences
  • mBridge after the handover by the BIS

Further Markets: UK, Switzerland, Singapore, UAE, Japan

Beyond the EU, US and China

Who supervises crypto services and stablecoins in five markets, how far legislation has progressed and what applies there to a stablecoin issued elsewhere. As of September 2026.

Key Points

  • UK: Digital Securities Sandbox and crypto regime from October 2027
  • Switzerland: DLT Act, FINMA practice and draft stablecoin law
  • Singapore, UAE, Japan: licences, stablecoin rules, central bank money
  • Dated status table, without a rating

Cross-Cutting: Compliance & Reporting

Travel Rule, DAC8, AML, Sanctions, Accounting

Which rules apply to a company using stablecoins, whom they oblige and what information the company provides. With the comparison of FASB, IFRS and HGB. As of September 2026.

Key Points

  • Travel rule and DAC8: what the provider needs from the company
  • Anti-Money Laundering Act, AMLR from 2027 and EU sanctions
  • Stablecoins on the balance sheet: FASB proposal, IFRS, HGB
  • Case study: one incoming payment, five rules

Comparison & Decision Support

EU, US, China & Further Markets

Nine jurisdictions in one table, rated with a traffic light that measures how far a rule has progressed in law. Plus what that means for the location of a first pilot.

Key Points

  • Traffic light with a measurement rule: issuance, foreign stablecoins, service providers, central bank money
  • EU versus US: e-money tokens and payment stablecoins
  • Passporting and reach across borders
  • Key dates until 2029 and interest rules compared