Anvesan

Stablecoins

Stablecoin license by country: which license an issuer needs, and from whom

The licence and regulator for stablecoin issuers in 55 regulated markets, the status in 80, from Sherpa's data, with the US, EU, UK and Hong Kong rules.

Anvesan ResearchUpdated

Summary

  • Sherpa classes 55 of 80 covered markets as regulated
  • US: federal or state approval, once GENIUS Act takes effect
  • EU: e-money or credit institution authorisation from home authority
  • UK: FCA e-money authorisation; new regime from 25 Oct 2027
  • Hong Kong: stablecoin issuer licence from the HKMA

A stablecoin licence is the authorisation or approval a stablecoin issuer needs from a regulator, and its name differs by market. Of the 80 markets for which Sherpa's signed-off data covers stablecoin issuance, read on 28 Sep 2026, it classes 55 as regulated, 22 as having no framework in force and 3 as prohibiting issuance. The table below gives the licence and the regulator for each regulated market.

How to read this guide

The table comes from Sherpa, Anvesan's licensing data, read on 28 Sep 2026 from its 27 Sep 2026 sign-off snapshot. It shows the licence Sherpa records for issuing a stablecoin in each market and the regulator Sherpa records for it. Where Sherpa records more than one licence for a market, the row lists each one. Each market name links to that market's stablecoin issuance path in Sherpa's Pathfinder, except the EU row, which links to Anvesan's MiCA licence guide.

The four sections after the table summarise the rules in the United States, the European Union, the United Kingdom and Hong Kong from official sources. For the other markets, see Anvesan's regimes index and the Atlas.

Which license, from whom: the regulated markets

Market Licence, as Sherpa records it Regulator
European Union (27 member states) Electronic money institution or credit institution authorisation The competent authority of the home member state (BaFin in Germany)
Australia Australian financial services licence Australian Securities and Investments Commission (ASIC)
Bermuda Digital asset business licence The Bermuda Monetary Authority (BMA)
Botswana Issuer of initial token offerings licence The Non-Bank Financial Institutions Regulatory Authority (NBFIRA)
Cameroon COSUMAF visa for a public offer of digital tokens Central African Financial Market Supervisory Commission (COSUMAF)
Cayman Islands Registration as a virtual asset service provider The Cayman Islands Monetary Authority (CIMA)
El Salvador Registration as an issuer, and authorisation of the public offering The National Commission of Digital Assets (CNAD)
Georgia Virtual asset service provider registration National Bank of Georgia
Gibraltar Part 7 permission for DLT Provider's or VAA Provider's business / Part 7 permission to issue electronic money (electronic money institution) The Gibraltar Financial Services Commission (GFSC)
Guernsey Part III virtual asset service provider (VASP) licence The Guernsey Financial Services Commission (GFSC)
Hong Kong Stablecoin issuer licence The Hong Kong Monetary Authority
Isle of Man Class 8 financial services licence (money transmission services) The Isle of Man Financial Services Authority (IOMFSA)
Israel Licence to provide a financial asset service Capital Market, Insurance and Savings Authority, Supervisor of Financial Service Providers
Jersey Consent under the Control of Borrowing Order for an initial coin or token offering Jersey Financial Services Commission (JFSC)
Kazakhstan Stablecoin issue under the National Bank's rules / AFSA licence for Providing Money Services National Bank of Kazakhstan / Astana Financial Services Authority (AFSA)
Kenya Virtual asset service provider licence (Central Bank of Kenya) The Central Bank of Kenya
Liechtenstein Electronic money institution or credit institution authorisation Finanzmarktaufsicht Liechtenstein (FMA)
Mauritius Registration as an issuer of initial token offerings The Financial Services Commission, Mauritius (FSC)
Mozambique Virtual asset service provider registration Banco de Moçambique
Namibia Token issuer licence / Payment service provider licence The Bank of Namibia, as the Regulatory Authority / The Bank of Namibia
Nigeria SEC registration as a virtual asset service provider The Securities and Exchange Commission, Nigeria (SEC)
Rwanda Approval to issue stablecoins The Capital Market Authority of Rwanda
Seychelles Registration of an initial coin offering The Financial Services Authority of Seychelles (FSA)
Switzerland Affiliation with a self-regulatory organisation (SRO) as a financial intermediary A self-regulatory organisation recognised and supervised by the Swiss Financial Market Supervisory Authority (FINMA)
Thailand Licence for designated payment services Bank of Thailand (licence granted by the Minister of Finance)
United Arab Emirates Dirham Payment Token Issuer licence / Financial Services Permission for virtual asset activities The Central Bank of the UAE (CBUAE) / The Financial Services Regulatory Authority (FSRA) of the Abu Dhabi Global Market
United Kingdom Authorisation as an electronic money institution The Financial Conduct Authority (FCA)
United States Approval as a permitted payment stablecoin issuer The Comptroller of the Currency, a Federal banking agency, the National Credit Union Administration, or a State payment stablecoin regulator
Uruguay Stable virtual asset issuer authorisation Banco Central del Uruguay, Superintendencia de Servicios Financieros

Sherpa classes stablecoin issuance as having no framework in force in Argentina, Brazil, Colombia, the Democratic Republic of the Congo, Eswatini, Ethiopia, Ghana, Indonesia, Lesotho, Malawi, Malaysia, Mexico, Morocco, Panama, Singapore, South Africa, South Korea, Taiwan, Türkiye, Uganda, Ukraine and Zambia. It classes it as prohibited in Egypt, Tanzania and Vietnam.

The United States: the GENIUS Act

The GENIUS Act, Public Law 119-27, was approved on 18 Jul 2025. Once the Act takes effect, section 3(a) makes it unlawful for any person other than a permitted payment stablecoin issuer to issue a payment stablecoin in the United States, subject to any limited safe harbours Treasury issues. A permitted issuer is a person formed in the United States that is one of three kinds: a subsidiary of an insured depository institution approved under section 5, a federal qualified issuer or a state qualified issuer approved by a State payment stablecoin regulator.

The Act takes effect on the earlier of 18 months after enactment or 120 days after the primary federal regulators issue final implementing regulations. Treasury expects 18 Jan 2027. The federal proposals so far are in Anvesan's guide to GENIUS Act regulations in 2026.

The European Union: MiCA

The Markets in Crypto-Assets Regulation (MiCA) sets two categories of token that aim to keep a stable value. An e-money token (EMT) purports to keep a stable value by referencing one official currency. An asset-referenced token (ART) is a token, other than an EMT, that purports to keep a stable value by referencing another value or right, or a combination, including one or more official currencies. The rules for both have applied since 30 Jun 2024.

  • EMTs. Only the issuer, or another person with the issuer's written consent, may offer an EMT to the public or seek its admission to trading in the EU. The issuer must be authorised as a credit institution or an electronic money institution and have notified and published a white paper, with limited exemptions. MiCA deems EMTs to be electronic money.
  • ARTs. To offer an ART to the public or seek its admission to trading, the issuer must be established in the EU and authorised by the competent authority of its home member state, or be a credit institution that meets MiCA's conditions, with limited exemptions for small issues and offers solely to qualified investors. Other persons may offer it with the issuer's written consent. An ART authorisation is valid for the entire Union.

The European Banking Authority reported that, as at 1 Sep 2026, 39 EMTs had been issued under MiCA, 36 of them by electronic money institutions, and no ART had been authorised. The routes are set out in Anvesan's MiCA licence guide.

The United Kingdom: the new cryptoasset regime

For issuing a stablecoin in the UK, Sherpa's signed-off data currently lists authorisation as an electronic money institution from the Financial Conduct Authority (FCA).

From 25 Oct 2027, the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 bring new regulated activities into the FCA's perimeter, including issuing qualifying stablecoins in the UK. Anyone carrying on those activities by way of business in the UK then needs FCA authorisation, unless an exemption applies or they can use the savings or transitional provisions. The FCA's application period runs from 30 Sep 2026 to 28 Feb 2027. Anvesan's guide to the FCA crypto licence covers the gateway.

Hong Kong: the Stablecoins Ordinance

Since the regulatory regime for stablecoin issuers under the Stablecoins Ordinance took effect on 1 Aug 2025, the business of issuing fiat-referenced stablecoins has been a regulated activity in Hong Kong that needs a licence from the Monetary Authority. On 10 Apr 2026 the Hong Kong Monetary Authority (HKMA) announced licences for Anchorpoint Financial Limited and The Hongkong and Shanghai Banking Corporation Limited, with effect that day. The HKMA's Chief Executive wrote the same day that if more licences are granted, the overall number will remain very limited. The requirements are in Anvesan's Hong Kong stablecoin licence guide.

Recent developments

  • 24 Sep 2026. The Federal Reserve Board proposed GENIUS Act rules for the issuers it supervises: see the News story.
  • 10 Apr 2026. The licences the Monetary Authority granted to Anchorpoint Financial Limited and The Hongkong and Shanghai Banking Corporation Limited took effect.

See the full path in Sherpa's Pathfinder.

Frequently asked questions

What is a stablecoin licence?

It is the authorisation or approval a stablecoin issuer needs from a regulator. The name differs by market: Hong Kong has a stablecoin issuer licence, the US approves permitted payment stablecoin issuers, and the EU requires an e-money token issuer that offers the token to the public or seeks its admission to trading to be authorised as a credit institution or an electronic money institution, with limited exemptions.

Which countries have stablecoin regulations?

Of the 80 markets for which Sherpa's signed-off data covers stablecoin issuance, read on 28 Sep 2026, it classes 55 as regulated (the 27 EU member states and 28 others), 22 as having no framework in force and 3 as prohibiting it. The table in this guide gives the licence and regulator for each regulated market.

Who regulates stablecoin issuers in the United States?

Under the GENIUS Act, a permitted payment stablecoin issuer is approved by the Comptroller of the Currency, a Federal banking agency, the National Credit Union Administration or a State payment stablecoin regulator. Treasury expects the Act to take effect on 18 Jan 2027.

Does the UK have a stablecoin licence?

For issuing a stablecoin in the UK, Sherpa's signed-off data lists authorisation as an electronic money institution from the Financial Conduct Authority (FCA). From 25 Oct 2027, issuing qualifying stablecoins in the UK becomes one of the new regulated cryptoasset activities, and anyone carrying on those activities by way of business in the UK needs FCA authorisation, unless an exemption or the savings or transitional provisions apply.

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