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

Circle Internet Financial Europe SAS issues the euro stablecoin EURC. In Abu Dhabi it is on the list of tokens that authorised financial firms in the Abu Dhabi Global Market (ADGM) free zone may use. In Dubai, a merchant outside the financial free zones may not accept the same token as payment for goods. Both rules apply in the same country, issued by two different regulators.

This article describes five markets outside the EU, the US and China: the United Kingdom, Switzerland, Singapore, the United Arab Emirates (UAE) and Japan. The three large jurisdictions have their own articles, on the Markets in Crypto-Assets Regulation (MiCAR), on the US laws CLARITY Act and GENIUS Act and on China and the e‑CNY. What applies in the five markets to a stablecoin issued somewhere else? The answer always depends on who needs a permission there: the issuer, the service provider or the company that accepts the token. All information reflects the position in September 2026.

Five Markets at Five Stages

The five markets are at very different points. In the United Kingdom and in Japan, new laws for crypto-assets have been passed but do not yet fully apply. In Switzerland and in Singapore, drafts of stablecoin laws are on the table. In the UAE, the central bank's regulation on payment tokens has applied since August 2024. The table summarises the position without rating the markets. A rating with traffic-light logic and the comparison with the EU, the US and China are in Comparison & Decision Support.

The United Kingdom Starts with Settlement

Since 8 January 2024, the Bank of England and the Financial Conduct Authority (FCA) have jointly run the Digital Securities Sandbox (DSS). In it, firms issue, trade and settle digital securities on distributed ledger technology (DLT). Derivatives and unbacked cryptocurrencies such as Bitcoin are excluded. The sandbox runs until 8 January 2029, and HM Treasury can extend it by legislation. Admission comes in stages. Firms with a first-stage approval include Euroclear, LSEG, Tradeweb, J.P. Morgan and HSBC. Live business requires the second stage, and according to the Bank of England's overview of 13 July 2026 only HSBC has reached it.

Since 30 June 2026, participants can apply to use stablecoins for settlement. The Bank of England admits overseas stablecoins if they are not pegged to sterling and meet minimum requirements. These include a right of redemption for all holders and backing of the kind the FCA requires from UK issuers. Each token is assessed individually. A euro stablecoin can therefore pay for digital securities in London, provided the Bank admits it.

Outside the sandbox, Parliament passed the Cryptoassets Regulations on 4 February 2026. Among other things, they make issuing stablecoins, custody, trading and staking subject to authorisation. Their full scope applies from 25 October 2027. The FCA published its final rules on 30 June 2026 and accepts applications from 30 September 2026 to 28 February 2027. According to the FCA, existing registrations under anti-money-laundering law do not convert automatically into an authorisation.

How far the law reaches across the border depends on the activity. Issuing a stablecoin requires authorisation if it takes place from an establishment in the United Kingdom. For trading, arranging, custody and staking, a provider from abroad is treated as active in the country if it serves consumers there and no intermediary authorised there stands in between. Under the law, consumers are individuals in the United Kingdom acting for a purpose other than any trade, business or profession.

For sterling stablecoins recognised as systemic, the Bank of England writes its own rules. In its policy statement of 22 June 2026, it drops the per-holder limits proposed in 2025. Instead, it temporarily caps issuance at £40 billion per stablecoin. In steady state, backing is to consist of 70 per cent short-term UK government debt and 30 per cent unremunerated deposits at the Bank of England. It intends to finalise the rules by the end of 2026. According to its update of March 2026, no decision has been made on a digital pound for households and businesses. The design phase ends in 2026.

Switzerland Adapted Its Civil Law First

Switzerland started at a different point: with the question of how a security on a blockchain exists in law. Since 1 February 2021, its law has recognised ledger-based securities, rights held and transferred in an electronic register. Since 1 August 2021, the DLT Act has been fully in force. It also created a separate licence for DLT trading facilities in the Financial Market Infrastructure Act. The Swiss Financial Market Supervisory Authority (FINMA) granted the first one on 18 March 2025 to BX Digital AG, part of the Börse Stuttgart group. Its offering is open only to supervised participants, usually banks.

Such transactions are paid for in two ways, both within the Swiss National Bank's (SNB) Helvetia pilot. On the SIX Digital Asset Platform, the SNB issues digital central bank money for financial institutions. Through a link to the Swiss Interbank Clearing (SIC) payment system, tokenised assets can also be settled in conventional central bank money. BX Digital uses this link. Helvetia runs until at least June 2028. In the SNB's words, the pilot is not a commitment to introduce digital central bank money on a permanent basis.

Switzerland does not yet have a law of its own for stablecoins. How FINMA supervises them is set out in its guidance 06/2024 of 26 July 2024. In it, FINMA notes that various issuers use default guarantees from banks and therefore often need no licence under banking law. According to FINMA, this creates risks both for the holders of the stablecoins and for the guaranteeing banks. It also points to heightened money-laundering risks.

A dedicated law is in preparation. On 22 October 2025, the Federal Council opened a consultation on amending the Financial Institutions Act, which ran until 6 February 2026. It provides for two new licences. Payment instrument institutions are to replace the existing fintech licence, without its cap of CHF 100 million in client funds. They may issue a special type of stablecoin. Crypto institutions are to provide services with crypto-assets. In September 2026, the State Secretariat for International Finance still names the consultation as the latest step. How Switzerland treats a stablecoin issued abroad is not answered in the publications of FINMA or the State Secretariat.

Singapore Requires a Licence for Business Abroad as Well

In Singapore, anyone who offers the buying and selling of crypto-assets, transfers them or holds them in custody for customers needs a licence from the Monetary Authority of Singapore (MAS). Since 30 June 2025, the licensing requirement has also covered providers that serve only customers abroad from Singapore. By its own account, MAS will generally not grant such licences, because money-laundering risks are higher in these business models. Existing providers of this kind had to cease this business on that date.

MAS set out its framework for stablecoins on 15 August 2023. It applies to stablecoins issued in Singapore and pegged to a single currency, the Singapore dollar or one of the G10 currencies. Only issuers that meet the requirements may describe their token as a "MAS-regulated stablecoin". The framework is not yet law. On 1 September 2026, MAS put the necessary amendments to the Payment Services Act out for consultation, with comments due by 16 October 2026.

Three points in the draft are new compared with 2023. MAS intends to recognise a limited number of foreign-issued stablecoins if they are subject to a comparable framework, citing cross-border wholesale use cases. Stablecoins issued jointly by a Singapore issuer and a foreign one are to be able to fall under the framework. And no interest is to be paid on regulated stablecoins. MAS treats all other stablecoins like other crypto-assets.

MAS tests tokenisation with the financial industry in Project Guardian, a cross-border programme for tokenised funds, bonds, stablecoins and bank liabilities. The Deutsche Bundesbank is one of the authorities in its policymaker group. Since October 2025, the BLOOM project has also been running. It aims to enable settlement in tokenised bank liabilities and regulated stablecoins and names corporate treasury management and trade finance among its use cases. On 13 November 2025, MAS issued digital central bank money for live interbank transactions for the first time. DBS, OCBC and UOB used it to settle overnight lending between them.

In the Emirates, Location Determines the Regulator

The UAE has no single supervisor for crypto-assets. In the Emirate of Dubai, the Virtual Assets Regulatory Authority (VARA) has been responsible since March 2022, except for the Dubai International Financial Centre (DIFC). There the Dubai Financial Services Authority (DFSA) supervises, and in the ADGM free zone the Financial Services Regulatory Authority (FSRA). At federal level, the Central Bank of the UAE (CBUAE) licenses payment services using crypto-assets. The Capital Market Authority (CMA) published its own framework for virtual assets on 13 April 2026. Which rule applies therefore depends on where a company is established and on what it does.

For payments, the central bank draws the line. Its Payment Token Services Regulation has applied since 31 August 2024 and provided for a one-year transition period that the central bank can extend. Licensed providers may transfer two kinds of token: dirham tokens from a licensed issuer for any lawful purpose, and foreign tokens from a registered issuer only for buying crypto-assets. A merchant in the UAE may accept only such a dirham token as payment for goods or services, and foreign tokens only when selling crypto-assets. Algorithmic stablecoins are banned outright. The regulation expressly exempts the financial free zones from these prohibitions.

There, the rules of their own regulator apply. The FSRA requires authorised financial firms in ADGM to use only stablecoins it has put on its list. The list of 1 September 2026 contains nine tokens, including EURC, USDC and Tether USD (USDT). According to the FSRA, a listed token does not relieve a holder of assessing the issuer and its reserves. Since 12 January 2026, the DFSA in the DIFC no longer maintains a prescribed list. Authorised firms there may only use tokens they have themselves assessed as suitable under DFSA requirements.

Under a federal law in force since 16 September 2025, currency in digital form issued by the central bank is legal tender. Across borders, the CBUAE is a founding member of mBridge, the multi-central-bank platform described in the article on China.

Japan Anchored Stablecoins in Payments Law

In Japan, an amendment to the Payment Services Act has applied since 1 June 2023 that covers stablecoins as electronic payment instruments. Anyone dealing in them for customers must register with the Financial Services Agency (FSA). On 27 August 2026, the register lists two such firms, SBI VC Trade and Coincheck. Both handle USDC, and SBI VC Trade also RLUSD and a token called JPYSC. In its own words, the FSA only confirms with the entry that a token meets the legal definition, not its value.

A further amendment has applied since 1 June 2026. Stablecoins issued through a trust arrangement may now invest their backing up to a cap in certain government bonds and term deposits that can be withdrawn early. The authorities can also order providers to hold assets in Japan. New is a category of intermediaries for stablecoins and crypto-assets.

For crypto-assets themselves, the legal basis is changing. On 15 July 2026, the Diet passed a law that regulates trading in crypto-assets no longer as a payment service but as trading in financial instruments. It adds rules on disclosing information and against insider trading. It was promulgated on 23 July 2026. It enters into force on a date set by cabinet order, at the latest one year after promulgation. Until then, the register under the Payment Services Act applies, which lists 27 exchanges and dealers on 1 September 2026.

The Bank of Japan is testing a digital yen in a pilot programme, and its latest progress report reflects the position in June 2026. In March 2026, it announced that it would also explore tokenised current account balances of banks at the central bank. That is digital central bank money for financial institutions. According to Executive Director Kazushige Kamiyama in May 2026, it also continues to study a central bank digital currency (CBDC) for the general public.

Spare Parts for USDC

A manufacturer of packaging machinery from East Westphalia runs a service and spare-parts company in Dubai, outside the financial free zones. Two customers in the Gulf ask whether they can pay for spare parts in USDC in future. The finance team in Germany is to clarify whether the subsidiary may do so. A second company in ADGM is also under discussion.

For the company in Dubai, the wording is clear. It sells goods and services in the UAE and may only accept dirham tokens from a licensed issuer for them. USDC is not such a token, wherever the customer is based. For a company in ADGM, the central bank's prohibitions do not apply. The FSRA list is of limited help there: it determines which stablecoins authorised financial firms may use and says nothing about selling machine parts. One exemption in the regulation concerns the group itself. It excludes transfers between parent and subsidiary as long as no service provider outside the group is involved. This does not cover a customer's payment, because the customer does not belong to the group.

For the finance team, the question thus moves from the token to the location. In the UAE, the answer depends on where the company itself is established, in the United Kingdom and in Singapore on the service provider's permission, and in Japan on the intermediary's registration. Anyone who sets up or relocates a subsidiary therefore also decides on its permitted payment routes. The anti-money-laundering, reporting and accounting obligations that apply to such payments in all markets are described in Cross-Cutting: Compliance & Reporting.

The greater risk lies in the rebuilding of the rules. In the United Kingdom, crypto services move into a new legal regime in October 2027, in Japan by July 2027 at the latest, and UK registrations do not carry over automatically. In Singapore and Switzerland, stablecoin laws exist as drafts, and their final form is open. A service provider a company works with today may lose its permission or change its offering during this transition. How holdings are kept and what happens if a custodian fails is described in Custody & Safekeeping.

Admission Lists Open Markets

Four of the five markets now have a way of admitting foreign stablecoins. ADGM keeps a list, the Bank of England assesses each token individually for its sandbox, Singapore intends to recognise a limited number, and in Japan the registration of intermediaries decides which tokens are traded. The DFSA, by contrast, has abolished its list and leaves the assessment to the firms. For an issuer, each of these gateways is a separate market access that no authorisation in the EU or the US provides. USDC is on the ADGM list and can be traded with both Japanese intermediaries. EURC is on the ADGM list and does not appear in the Japanese register. In the competition outside the three large jurisdictions, what counts for an issuer is therefore the number of gateways that have admitted its token. For a German company choosing a euro stablecoin, this number is one of the token's properties, just like its backing.