The Financial Stability Institute at the Bank for International Settlements published FSI Brief No. 33, titled Regulating stablecoin issuance: permissible entities and activities, on 27 August 2026. The brief is a comparative regulatory analysis, not a binding rule or standard. It reflects the Financial Stability Board's ongoing work on cryptoasset implementation and is intended to inform national regulators as they move from policy commitment to rulemaking.
The brief analyses five jurisdictions on two dimensions: which entity types may issue fiat-referenced stablecoins, and which ancillary activities those issuers may conduct alongside issuance. Under the EU's Markets in Crypto-Assets Regulation, Article 48 restricts issuance to credit institutions authorised under Directive 2013/36/EU and electronic money institutions authorised under Directive 2009/110/EC. The brief identifies MiCA's entity-type restriction as the most prescriptive of the surveyed regimes. By contrast, several surveyed jurisdictions permit non-bank trust companies or licensed payment firms to issue fiat-referenced tokens. Treatment of foreign issuers also varies: MiCA requires EU authorisation for any public offer regardless of issuer domicile.
Crypto asset service providers, payment institutions, and technology companies planning to issue EUR- or GBP-referenced stablecoins to the public will find the comparative matrix directly relevant to licensing decisions. MiCA's entity restriction prevents pure-play fintech issuers from conducting public EUR stablecoin offerings without a credit institution or e-money licence, creating demand for chartered entity acquisition or licensing agreements with authorised institutions. Jurisdictions that permit non-bank issuers produce regulatory arbitrage incentives that multinational issuers exploit through domicile selection. Custodians and reserve managers serving stablecoin issuers must also account for jurisdiction-specific restrictions on permissible reserve instruments.
The brief covers only fiat-referenced stablecoins and does not address algorithmic or crypto-collateralised tokens. Several surveyed jurisdictions had pending legislative proposals at time of publication, so the comparative picture will shift. The brief acknowledges that the absence of a global baseline for issuer permissibility sustains cross-border fragmentation and creates ongoing arbitrage risk.
Licentium may advise on matters arising from this publication or connect clients with counsel in our partner network. Work we undertake includes MiCA compliance advisory, stablecoin licensing strategy across multiple jurisdictions, electronic money institution licensing, and cross-border crypto asset regulatory analysis.