Three major stablecoin regulatory regimes came online between 2024 and 2025: the EU's Markets in Crypto-Assets Regulation (MiCA), the US Guiding and Establishing National Innovation for US Stablecoins Act (GENIUS Act), and the UK Financial Conduct Authority's stablecoin and custody framework. Each addresses payment stablecoins through reserve, capital, and authorization requirements, but the three regimes diverge in ways that produce material operational differences for issuers and service providers operating across jurisdictions. This article compares MiCA, GENIUS, and the FCA framework on the seven dimensions that matter most: scope, authorization, eligible reserves, yield prohibition, custody, foreign-currency limits, and cross-border passporting.
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The texts referenced below are Regulation (EU) 2023/1114 for MiCA, S.394 GENIUS Act as enacted in July 2025, and the UK FCA's CP25/15 consultation on stablecoin issuance and custody published in May 2025.
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MiCA is the broadest in scope. The regulation covers e-money tokens, asset-referenced tokens, and a residual category of "other crypto-assets" including utility tokens. Stablecoin rules under Titles III and IV apply from 30 June 2024; service provider rules under Title V apply from 30 December 2024. Coverage extends to issuance, public offers, admission to trading, and the conduct of crypto-asset service providers across all 27 EU member states, plus Iceland, Liechtenstein, and Norway through EEA application.
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The GENIUS Act covers payment stablecoins specifically, defined as digital assets pegged to a fixed monetary value redeemable on demand at par. The Act creates a federal payment-stablecoin license issued by the Office of the Comptroller of the Currency (OCC) for non-bank issuers and supervised by federal banking regulators for bank issuers. State-level money-transmitter and trust-charter regimes (notably the New York Department of Financial Services BitLicense and Trust Charter) continue to operate alongside the federal regime, with reciprocal recognition for state-licensed issuers below USD 10 billion in outstanding stablecoins.
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The UK FCA framework covers stablecoins issued or marketed to UK customers, with separate workstreams for issuance, custody, and trading. Stablecoin issuance falls under FSMA-amended primary legislation, with FCA conduct rules layered on top. The framework is staged: stablecoin issuer authorization opened in early 2025; custody and trading rules are scheduled for staged commencement through 2026.
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The three regimes differ in who can issue.
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Under MiCA, EMT issuers must be a credit institution under CRD IV/V or an electronic money institution under EMD2. ART issuers must be a legal person established in the EU. Both routes require home-state authorization that passports across all member states.
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Under the GENIUS Act, issuers may be a federally chartered bank, a state-chartered bank with reciprocal recognition, an OCC-licensed federal payment stablecoin issuer (a new license type created by the Act), or a state-licensed trust company below the USD 10 billion threshold. The federal license has materially lower minimum capital requirements than EMI authorization under MiCA, with the OCC license imposing capital requirements that scale with reserves.
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Under the UK FCA framework, issuers must be FCA-authorized as a stablecoin issuer under Part 4A of the Financial Services and Markets Act, with separate sub-categories for fiat-backed and other-backed stablecoins. The FCA permits more issuer-structure flexibility than MiCA, including non-bank issuers without an existing financial-services license, provided they meet capital and operational resilience requirements specific to stablecoin operations.
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The practical authorization timeline:

Reserve composition is where the three regimes diverge most. MiCA requires a minimum 30% bank-deposit floor for non-significant tokens, rising to 60% for significant tokens. The remainder may be held in highly liquid, low-risk financial instruments with weighted average maturity capped at three months for non-significant and one month for significant.
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The GENIUS Act takes a narrower view of eligible reserves. Reserves must be held in:

The Act excludes commercial paper, corporate bonds, money-market funds, and any non-USD-denominated instrument from eligible reserves. This is a tighter scope than MiCA and produces a more uniformly conservative reserve composition across US-licensed issuers.
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The FCA framework, as proposed in CP25/15, mirrors GENIUS more closely than MiCA. Eligible reserves are restricted to cash deposits at UK or equivalent-jurisdiction credit institutions, short-dated UK or equivalent sovereign debt, and qualifying money-market fund holdings. The FCA proposal does not impose a percentage floor on bank deposits but does require the issuer to demonstrate that the reserve composition is fit for the redemption profile.
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All three regimes prohibit yield to retail holders of payment stablecoins. The mechanism differs.
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MiCA Article 50 prohibits EMT issuers from paying interest, rewards, or any benefit linked to the holding period. ART issuers face the same prohibition under Article 40. The prohibition is absolute: no holder of a MiCA-authorized payment stablecoin may receive yield from the issuer.
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The GENIUS Act prohibits payment stablecoin issuers from paying yield to holders, with the same absolute structure as MiCA. Yield-bearing tokens that derive return from delta-neutral derivatives (such as Ethena's USDe) or from underlying tokenized instruments (such as Ondo's USDY) fall outside payment-stablecoin scope and may be regulated as securities under SEC jurisdiction or as money-market funds under the Investment Company Act.
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The FCA framework permits yield only on segregated regulated-money-market-fund tokens, not on payment stablecoins. The distinction allows tokenized money-market funds to operate under existing investment-fund rules while keeping payment stablecoins yield-free. The FCA approach is therefore the most differentiated of the three: yield-bearing tokenized cash is regulated as fund product, payment stablecoins as a distinct asset type.
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MiCA requires reserve assets to be held with a third-party custodian segregated from the issuer's balance sheet. For cash, the custodian must be an EU-licensed credit institution. For investment-grade instruments, the custodian must be an EU-licensed CSD, credit institution, or MiFID investment firm. Concentration limits cap exposure to any single custodian.
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The GENIUS Act requires reserves at insured depository institutions or in Federal Reserve master accounts (for bank issuers). The Act also creates a "qualified custodian" category for the OCC-licensed federal stablecoin issuer track, with custody at federally insured banks or at trust companies meeting specific operational standards.
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The FCA proposal follows MiCA's segregation principle but adopts looser custodian eligibility, permitting non-bank custodians that meet operational resilience and segregation standards. This reflects the FCA's broader approach of regulating activity outcomes rather than institution types.
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The largest divergence between the three regimes is on foreign-currency stablecoins. MiCA Article 58 imposes a transactional cap on significant EMTs denominated in non-EU currencies: 1 million transactions per day or EUR 200 million per day in transaction volume, whichever is reached first, when used as a means of exchange in the EU. The cap is intended to limit dollar-stablecoin penetration of EU payment markets, a stated policy goal of the European Central Bank.
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The GENIUS Act contains no analogous cap. US-licensed payment stablecoins denominated in any currency may circulate freely under the federal license, with reserve composition rules tailored to the reference currency.
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The FCA proposal does not contain a foreign-currency cap on inbound stablecoins but does impose stricter disclosure and risk-warning requirements on non-GBP-denominated stablecoins offered to UK retail customers.
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Cross-border passporting is similarly different:

Issuers operating across multiple regimes face structural choices. Circle Internet Financial maintains separate authorization stacks: French EMI authorization for USDC and EURC under MiCA, US trust company status through Circle Mint USA for the US market, and engagement with the FCA framework for UK customer onboarding. Circle's framework treats each regime as a separate compliance perimeter, with reserve composition and disclosure tuned to local rules.
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Tether, by contrast, has pursued the GENIUS Act path through the USAT-branded US-domiciled stablecoin issued in partnership with Anchorage Digital Bank. USDT itself remains unauthorized under MiCA and effectively delisted from EU venues. Tether has not pursued FCA authorization as of late 2025.
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Paxos Trust Company NY operates USDP under NY DFS Trust Charter and Pax Gold (PAXG) under similar state-level authorization. Paxos pursued MiCA authorization for PYUSD through Paxos Issuance Europe in Malta, with authorization expected in late 2025.
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Stablecoin orchestration platforms must reflect regime-specific routing logic. A USDC transfer that begins with a US customer and ends with an EU customer crosses two regulatory perimeters: the GENIUS Act on the US side (where Circle's federal license applies) and MiCA on the EU side (where Circle's French EMI license applies). The token is the same; the regulatory wrapping at each endpoint differs. Eco tags each route leg with the applicable regulatory regime based on the customer's jurisdiction, the issuer's authorization basis, and the venue type. Across the 15 chains Eco supports, this lets developer teams build cross-border payment flows that respect endpoint regulation without rewriting integrations per jurisdiction. The orchestration logic that selects between CCTP, Hyperlane, and LayerZero on cost and finality also reads the regime-tags and gates routes accordingly.
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Related reading. Related reading in the MiCA cluster: the MiCA pillar overview, reserve and authorization rules, and using stablecoins legally in the EU.
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MiCA is the strictest on reserve composition due to the bank-deposit floor and the foreign-currency cap on significant EMTs. The GENIUS Act is stricter on eligible instruments (Treasuries-only). The FCA framework is more permissive on issuer structure but stricter on operational resilience disclosures.
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Not directly. The issuer would need to obtain MiCA authorization through an EU subsidiary or partner with an existing EU-licensed entity to issue a MiCA-compliant variant. Equivalence-based recognition of US licenses is not in scope under MiCA's current text.
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For federally licensed payment stablecoin issuers, yes, with limited carve-outs. State-licensed issuers below USD 10 billion in outstanding tokens may continue under state law with reciprocal federal recognition. Above the threshold, federal license is required.
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Stablecoin issuer authorization opened in early 2025. Custody and trading rules are staged through 2026. Final commencement dates depend on parliamentary timing and FCA rulebook finalization.
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Yes, but each authorization is separate. The same brand-name stablecoin may circulate in multiple regimes if the issuer obtains authorization in each. Circle operates USDC under both MiCA (via French EMI license) and the US framework (via state trust charters). Reserve segregation by regime is typically required.
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