The United Kingdom and the United States each published stablecoin regulatory instruments in 2025 and 2026 that are structurally parallel but operationally distinct. In the UK, S.I. 2026/102, the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026, and the FCA's final rules published on 30 June 2026 establish a licensing and conduct regime for qualifying stablecoin issuers, operative from 25 October 2027. In the United States, the Guiding and Establishing National Innovation for US Stablecoins Act (the GENIUS Act), enacted on 18 July 2025, establishes a federal licensing regime for payment stablecoin issuers with a parallel state licensing path, with issuer authorisation required no later than January 2027.
Under S.I. 2026/102, issuing a qualifying stablecoin is a regulated activity in the United Kingdom requiring FCA authorisation. The FCA's final rules require UK-issued qualifying stablecoins to be fully backed at all times and to carry guaranteed par-value redemption rights. Under the GENIUS Act, payment stablecoin issuers must hold reserves consisting of US dollars, Federal Reserve deposits, short-term US Treasury securities, or qualifying central bank reserves, subject to 1:1 backing requirements at all times. The Office of the Comptroller of the Currency issued a Notice of Proposed Rulemaking in 2026 to implement the GENIUS Act's licensing requirements for nationally chartered payment stablecoin issuers.
Stablecoin issuers seeking to operate in both the UK and US markets must obtain separate regulatory authorisations in each jurisdiction. UK-based issuers must apply to the FCA between 30 September 2026 and 28 February 2027 and meet the Bank of England's backing and redemption standards. US-based issuers must obtain a national bank charter, Federal Reserve membership, or state charter approval, with the applicable reserve requirements differing by charter type. Issuers holding reserves in non-USD assets face additional complexity in demonstrating 1:1 backing compliance across both regimes.
The two regimes differ in their treatment of stablecoin payment activities. The UK proposes to exclude qualifying stablecoin payment activities from the new arranging and dealing regulated activities pending a future payments regime, creating interim uncertainty for UK payment processors. In the US, the GENIUS Act preempts state licensing requirements for nationally chartered issuers, though state-chartered issuers remain subject to state law. Neither regime includes a mutual recognition mechanism, so dual-jurisdiction stablecoin issuers must maintain separate compliance programmes in each market.
We advise stablecoin issuers on authorisation and compliance requirements in the UK and US and may assist through our partner network. Contact us for analysis of your stablecoin programme against the requirements of S.I. 2026/102, the FCA's final rules, or the GENIUS Act. Work we undertake includes stablecoin regulatory assessments, FCA authorisation advisory, GENIUS Act compliance analysis, cross-border issuer structuring, and asset reserve and redemption policy review.
Source: Financial Conduct Authority, Overview of Cryptoassets Regime Policy Statements, 30 June 2026