Stablecoin regulation: how rules aim to cut peg risk

What problem do stablecoin rules aim to solve?

A stablecoin promises redemption at par, and a promise needs a backstop. Without rules, an issuer can choose its own reserve mix, its own disclosure, and its own redemption terms. Holders then judge each token alone, and a doubt about one issuer can spread to others. Rules aim to make the promise comparable, so that holders judge categories instead of rumours.

The most common failure channel is the run: holders redeem or sell at once, and reserves fall short of demand. Rules target the run by requiring liquid reserves, clear redemption rights, and regular reports. FATF figures reported in October 2025 show that about 95% of stablecoins are fiat-backed, so reserve rules reach most of the market.

Which 5 rule tools cut stablecoin peg risk?

Five tools recur across regimes. Reserve rules set what assets back each token. Redemption rights set who can exchange tokens for money, how fast, and at what cost. Disclosure rules set what the issuer publishes and how often. Licensing sets who may issue. Activity limits restrict risky uses of reserves and of customer money. Each tool addresses a different link in the chain of a run.

No single tool is enough. Strong reserves with slow redemption still leave holders waiting, and fast redemption with weak reserves only moves the run to the issuer. Regimes therefore combine tools, and a holder can score any regime by asking which of the five tools it contains and how precisely it defines each.

How does MiCA treat stablecoins in the European Union?

The Markets in Crypto-Assets Regulation, known as MiCA, entered into force in June 2023. According to Wikipedia, its provisions on asset-referenced tokens and e-money tokens applied from 30 June 2024, and the remaining crypto-asset rules followed on 30 December 2024. The two token classes cover stablecoins tied to a basket of assets and stablecoins tied to a single official currency.

ESMA keeps an interim register with separate files for issuers of asset-referenced tokens and issuers of e-money tokens, plus white papers for each class. Wikipedia notes that Société Générale listed a stablecoin on Bitstamp in December 2023, described as the first major bank to do so under MiCA. A holder can use the register to check whether an issuer is authorised.

How does the American stablecoin approach differ from the European one?

The GENIUS Act, signed on 18 July 2025, takes a different route. It requires payment stablecoins to be backed one-for-one by US dollars or other low-risk assets, and it removes compliant payment stablecoins from the federal definitions of security and commodity, according to Wikipedia. The Act therefore focuses on payment use and the issuer, while MiCA sorts tokens by what they reference.

Brookings analyses, cited by Wikipedia, add that GENIUS-regulated stablecoins are not bank deposits, so they lack FDIC insurance and direct Federal Reserve access. The comparison shows a shared aim and different tools. Both regimes want reserves behind tokens, and each defines issuers, reserves, and supervisors in its own way. A dedicated guide in this series covers the Act in detail.

Which other jurisdictions are building stablecoin rules?

The United Kingdom moves on its own path. According to Wikipedia, Bank of England Governor Andrew Bailey wrote on 1 October 2025 that widely used stablecoins should be regulated like money, and the Bank published a consultation paper on 27 March 2026 for sterling systemic stablecoins. The UK approach focuses on tokens large enough to matter for the financial system.

In Asia and the Gulf, regulators build their own frameworks. Wikipedia reports that the UAE introduced regulations in June 2024, and that the Monetary Authority of Singapore finalised its approach and consulted on legislative amendments, a step reported in September 2026. Readers in Singapore, ASEAN, and Hong Kong should check the local regime that covers each token they hold.

What limits remain in stablecoin regulation today?

Rules cut the likelihood of a run and leave a residual risk. Disclosure arrives after the fact, so a report shows last month, not today. Reserves in bank deposits still depend on the bank, and the USDC episode of March 2023 showed how a bank failure can reach a token. Smart contract flaws stay outside most reserve rules, because code risk differs from asset risk.

Cross-border issuance adds a second limit. Wikipedia notes that MiCA has no clear rules for global firms that issue the same stablecoin from both an EU entity and a third-country entity, which raises concern that EU reserves could be quickly depleted in large redemptions. Rules also change, so a regime read in one quarter needs a reread in the next.

How can a holder use stablecoin rules in a risk review?

Turn the rules into 5 questions. Which regime covers this issuer, and is the issuer authorised there? What reserve rule applies? What redemption right does the holder have? How often does the issuer publish, and who checks the report? Which supervisor can act in a stress event? Write the answers with a date and compare them each quarter.

Answers vary by token and by place, so avoid assuming that one licence covers every product. This page is general information, not investment advice. The EQOS Asia method page explains the scoring behind this series, and a 30-minute pre-diagnostic applies it to the stablecoins in your treasury.

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About the author

Stéphane Jambu

President, EQOS Forecast Asia

Stéphane Jambu leads EQOS Forecast Asia and works as a consultant in e-commerce, search visibility, and AI. LinkedIn profile