Comparison & Decision Support

In six of the nine jurisdictions described in this regulation series, the rules for stablecoins are addressed to issuers or service providers: in the EU, the US, Hong Kong, the United Kingdom, Singapore and Japan. Whether a company there can accept a token depends on the permission of whoever issues or intermediates it, not on a permission of its own. In two jurisdictions, the rule starts with the means of payment itself. On the Chinese mainland, virtual currencies may not circulate as money, and Tether is named expressly. On the mainland of the United Arab Emirates (UAE), a merchant may accept only dirham tokens for goods and services. For Switzerland, the sources give no answer.

This article places the nine jurisdictions side by side and rates them with a traffic light. Its material comes from five articles of the series: on MiCAR, on the US, on China, on the further markets and on compliance and reporting. The article on the digital euro adds to it. The text reflects the position in September 2026.

What the Traffic Light Measures

A traffic light across markets looks objective and rarely is. Green then often just means that someone considers a market suitable. This traffic light therefore measures something narrow that can be checked: how far a rule has progressed in law. Every cell of the table gets one of five levels:

• in force: The rule is in force and applicable.
• adopted: The rule has been passed but only becomes applicable on a stated date.
• in preparation: There is a draft, a consultation, a pilot or an ongoing procedure, but no applicable rule.
• excluded: A rule in force prohibits it.
• open: The official sources read for the series do not answer the question.

"Open" gets no colour, because a missing answer is neither a permission nor a prohibition. "Not examined" means something else: the series has not read up on the question for that jurisdiction.

What is not measured is whether a market suits a particular business. That depends on the business, and none of the sources says anything about it. Nor does the article give an overall score per jurisdiction. Anyone who adds cells up has to weight them, and every weighting would be an opinion. Instead, the purpose leads to the relevant column. To accept payments, read the columns on foreign stablecoins and on service providers. To hold a balance, read the column on issuance, because redemption and priority in insolvency sit there. To run a subsidiary in a market, read the row of its seat.

Nine Jurisdictions, Four Questions

The table asks each jurisdiction four questions: under which rule stablecoins may be issued, whether foreign stablecoins get in, what a service provider needs and how far digital central bank money has come.

The EU and Japan each have three green cells. China is red in three columns and green in the fourth: its own digital money is in force, everything private is excluded. The US is yellow in all four columns, the United Kingdom and Singapore in three. Much has been passed or is under way there, and little is applicable.

The UAE has just as many green cells, and yet a merchant on its mainland may not accept a foreign stablecoin. This shows the limit of the measurement rule. Green means that the rule is settled. Whether it permits what a company intends is in the text of the cell and in the article behind it.

Two Routes to a Regulated Stablecoin

The EU and the US regulate the same subject with a different cut. In the EU, the token pegged to one currency is called an e-money token, in the US a payment stablecoin. Only a credit institution or an electronic money institution may issue an e-money token. The holder can redeem it at par at any time, free of charge. In the US, the issuer has to be incorporated there and authorised by one of three routes. Every token must be backed by a reserve of at least one to one, and the law lists what it may consist of. In insolvency, the holders' claims on the reserve rank ahead of all other creditors.

On the interest ban, the EU is stricter. Neither the issuer nor a service provider may pay interest on e-money tokens, while in the US the ban applies only to the issuer. The biggest difference, however, is time. The rules for e-money tokens have applied since 30 June 2024, the GENIUS Act takes effect by 18 January 2027 at the latest.

There is no bridge between the two frameworks today. The GENIUS Act provides for one: the US Treasury can recognise another country's supervision as comparable. An issuer from there can then reach US customers after 18 July 2028 as well. To do so, it must be registered with the Office of the Comptroller of the Currency (OCC), hold enough reserves in the US and be able to comply technically with orders of the US authorities. In September 2026, no such recognition had been published, including none for MiCAR.

In the other direction, MiCAR has no recognition. Under Article 48, only the issuer of an e-money token may offer it to the public in the Union. It must be authorised as a credit institution or electronic money institution and have notified a white paper. Others may offer it with the written consent of that issuer. A US issuer therefore needs the same authorisation for the European market as a European one.

How Far a Rule Reaches Across the Border

Passporting and extraterritoriality concern two directions. The first is how far an authorisation carries beyond its jurisdiction. The second is how far a jurisdiction reaches out to providers from elsewhere.

A true passport exists only in the EU. After notifying its home authority, an authorised crypto-asset service provider may operate in all member states without being present there. Outside the Union, this authorisation opens none of the eight other jurisdictions. The list in Abu Dhabi, the case-by-case review of the Bank of England and the planned recognition in Singapore each assess every token themselves.

Outwards, the jurisdictions reach in different ways. The EU ties in with the client. A provider from outside needs no authorisation as long as a client in the EU approaches it exclusively on its own initiative. Once it solicits clients, the exemption no longer applies. In addition, Article 48 deems an e-money token referencing the currency of a member state to be offered to the public in the Union, wherever its issuer is based. The United Kingdom ties dealing, arranging and custody to the consumer. A provider from abroad counts as operating in the country if it serves private individuals there and no locally authorised intermediary stands in between. The US ties in with the platform: from 18 July 2028, service providers may offer customers in the US only tokens of authorised or recognised issuers.

China reaches furthest. Providers from outside may not offer services involving virtual currencies in any form to companies and individuals on the mainland. Without the consent of the authorities, no one may issue a stablecoin pegged to the renminbi outside the mainland. Singapore takes the opposite route and regulates what happens from its own territory. Since 30 June 2025, providers that serve only clients abroad from there also need a licence. The Monetary Authority of Singapore (MAS) generally does not intend to grant such licences.

A company therefore has to check every service provider outside the EU for the authorisation or exemption it relies on. A client can hardly verify the exemption for requests on its own initiative, as the article on MiCAR describes.

Central Bank Money, Two Opposite Answers

In the column on digital central bank money, the jurisdictions are furthest apart. The digital euro is designed as a Central Bank Digital Currency (CBDC), as the counterpart to cash. It is not meant to bear interest, and for the holding limit the ECB has modelled up to 3,000 euros per person. The limit is meant to stop bank deposits from migrating into central bank money. There is no law. The European Parliament adopted its mandate for the negotiations with the Council in July 2026. A first issuance is possible in the course of 2029 at the earliest.

The e‑CNY has gone the opposite way. According to the People's Bank of China, a balance in the wallet of a commercial bank has been an interest-bearing deposit with that bank since 1 January 2026. Deposit insurance covers it. The digital euro is meant to take as few deposits from the banks as possible, while the e‑CNY has itself become a deposit.

The other jurisdictions are testing digital central bank money mainly between financial institutions. The Swiss National Bank issues it to financial institutions in the Helvetia pilot. In November 2025, Singapore used it for the first time to settle real transactions between banks. The UAE has declared its digital central bank money legal tender by law. The United Kingdom and Japan have not decided on issuance to the general public. In the US, the House version of the CLARITY Act would rule out a CBDC as a tool of monetary policy.

A similar pattern shows in the settlement of tokenised securities. In the Bank of England's digital securities sandbox, participants have been able to apply since 30 June 2026 to use stablecoins for settlement, foreign ones included. Switzerland settles in central bank money through Helvetia. Singapore wants to use tokenised bank liabilities and regulated stablecoins in Project BLOOM. On the Chinese mainland, the tokenisation of real-world assets is prohibited unless the regulator has approved it.

Key Dates until 2029

An indicator of "time to go-live" would have to predict when a company can start in a market. That depends on providers, banks and the company's own project, and no source contains it. What is documented are the days on which a cell of the table can change:

The steps that would change most have no date. They include a new vote on the CLARITY Act, the first recognition under the GENIUS Act, the submission of the Swiss stablecoin law to parliament and further licences in Hong Kong. The deadlines for tax reporting and anti-money-laundering checks are in the cross-section on compliance and reporting.

One Pilot, Four Locations

A manufacturer of laboratory equipment from Hesse, with revenue of around 250 million euros, sells through subsidiaries in New Jersey, Singapore, Basel and Dubai. The Dubai company sits outside the financial free zones. Customers in all four markets have asked about paying in stablecoins. The finance function is to propose to management where a first pilot for incoming payments can run. Its paper sorts the locations into three groups using the table, because each contains a different kind of no.

The parent company and Dubai can be decided today, with opposite results. In Germany, the rules for e-money tokens and service providers apply, and a euro token can be accepted through an authorised service provider. In Dubai, the subsidiary may accept only dirham tokens of a licensed issuer for equipment and service. The no there is a question of location. Only a company in a financial free zone could change it, and even there the lists govern financial firms, not the sale of equipment.

New Jersey and Singapore are tied to a date. The GENIUS Act protects the US subsidiary only once it takes effect, and the Senate has not decided on federal supervision of the platforms. In Singapore, the service provider needs a licence from the MAS, but which foreign stablecoins are recognised there is set out only in the draft. The no here reads "not yet".

Basel cannot be decided. Neither the Swiss Financial Market Supervisory Authority (FINMA) nor the State Secretariat for International Finance says how Switzerland treats a stablecoin issued abroad. Only a legal opinion helps here, and the paper says so instead of assigning a colour.

Management approves a pilot at the parent company. The US subsidiary returns to the agenda in January 2027, Singapore after the end of the consultation. The risk of the plan lies in the yellow cells. Planning on "adopted" or "in preparation" means planning on a rule that can still change before it applies. In the United Kingdom and in Japan, crypto services will even move to a different body of law in 2027, and British registrations will not convert automatically. How the balance from the pilot shows up in the accounts, tax reporting and anti-money-laundering checks is described in the cross-section on compliance and reporting.

Interest Draws the Line to the Banks

One question is missing from the table, because the sources answer it only for some jurisdictions: who may pay interest on a balance held in digital money. Where they do answer, they point the same way. In the EU, neither the issuer nor a service provider may pay interest on e-money tokens. In the US, it is prohibited for the issuer. The Senate version of the CLARITY Act would extend the ban to platforms, on the stated ground that such payments could weaken the role of banks. Singapore also intends to rule out interest on regulated stablecoins. In China, the banks pay interest on the e‑CNY in their wallets, that is, on a deposit, and private stablecoins are prohibited. MiCAR and the GENIUS Act both exclude deposits themselves from their scope, including as a tokenised deposit.

Competition between banks and stablecoin issuers is thus decided on yield. Where the rule is already settled, interest belongs to the deposit and not to the token. It remains open only where a rule leaves a gap, most clearly with the US platform that the GENIUS Act's interest ban does not cover. An offer of yield on a stablecoin balance therefore sits in exactly the part of the table that is still being negotiated. For the treasury of a German company, this means: under the rules in force, interest-bearing digital liquidity comes as a bank deposit, including in tokenised form.