EBI drops stablecoin regulation comparison for UK, US and EU

Stablecoin regulation is not just technical policy. It reflects deeper choices about who gets to issue money, how it is controlled, and how private money interacts with the banking system.

Here are key takeaways from EBI - European Banking Institute's latest report on stablecoin regulations comparison for UK, US and EU.

1️⃣ Stablecoins are now treated as money-like instruments

All jurisdictions converge on one point:

Stablecoins perform payment + store of value functions

Therefore they require:

- Prudential regulation

- Reserve backing

- Redemption guarantees

2️⃣ Three fundamentally different regulatory philosophies

🇪🇺 EU (MiCAR): Comprehensive, prescriptive, unified framework

MiCAR creates new categories:

- Asset-Referenced Tokens (ARTs)

- E-Money Tokens (EMTs)

MiCAR places strong emphasis on:

- Market structure

- Investor protection

- Uniform rules across EU

👉 Philosophy: “Control the entire market structure upfront”

🇺🇸 US (GENIUS Act): Narrow, stablecoin-focused

GENIUS treats stablecoins like:

- money market funds / narrow banks

GENIUS key features:

- 1:1 backing with safe assets (Treasuries, cash)

- Strong redemption rights

- Bank-style supervision

👉 Philosophy: “Make stablecoins safe payment instruments inside a banking logic”

🇬🇧 UK (FSMA-based regime)

Integration into existing financial regulation

Uses:

- e-money rules

- payment systems framework

Two-tier system:

- FCA (firm-level)

- Bank of England (systemic)

👉 Philosophy: “If it behaves like money, regulate it as money”

3️⃣ Reserve design = the biggest divergence

US: Treasuries, cash, short-term repos

EU: flexible but risk-based

UK: middle ground (similar to e-money)

Implication: No global standard, jurisdiction-specific stablecoins, not global ones

➡️ Bottom line

Stablecoins are being pulled into the regulated financial system with increasing alignment to banking, payments and capital markets infrastructure.

Because of differences in definitions, reserve rules and licensing models, global issuers must restructure per jurisdiction or launch separate products.

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