Where should you issue a stablecoin? Six markets compared

Stablecoin approval is most clearly on the record in the EU and Hong Kong, which both publish registers of licensed issuers. ESMA’s register listed 25 e-money token issuers at its 30 September 2026 update, and the HKMA granted Hong Kong’s first two licences on 10 April 2026. The UAE licenses dirham tokens through its Central Bank, the US is still writing its GENIUS Act rules, Singapore is still legislating and India has no regime. The best regulated market for a fiat-backed stablecoin is the one your reference currency and first users point at. That means the EU for a euro token, Hong Kong for a Hong Kong dollar token, the CBUAE for a dirham token, and the US for a dollar token once its rules are final.

No market makes stablecoin issuance easy. They make it possible in different shapes. The EU runs the only live, passportable issuance track, and its register proves it: 25 e-money token issuers at 30 September 2026, up from 21 at the 31 July update, and still zero asset-referenced ones. Hong Kong is live, narrow and unpassported.

The US has a statute but not yet its rules, so it rewards positioning rather than applications. The UAE works, with a hard fork at the dirham: reference AED and the Central Bank owns you; anything else belongs to the zone regulators. Singapore’s lane is set and deliberately narrow, but its single-currency stablecoin framework is still being written into law. India has no lane at all. “Easiest” is the wrong question; “approvable where my users and banking actually are” is the one that pays.

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Six markets at a glance

Schedule A · Where issuance stands, market by market
Market	Who authorises an issuer	What exists today	The catch
European Union	The member-state regulator, under MiCA’s e-money token and asset-referenced token regimes	The only live, passportable track: 25 EMT issuers on 50 register lines across 13 member states and Iceland, and zero ART issuers, per the ESMA register updated 30 September 2026 (21 issuers in 12 member states at the 31 July update)	E-money discipline, and a statutory ban on paying interest to holders
Hong Kong	The Monetary Authority (HKMA), under the Stablecoins Ordinance (Cap. 656), in force since 1 August 2025	A live licensing regime: the first two licences, to Anchorpoint Financial Limited and The Hongkong and Shanghai Banking Corporation Limited, took effect on 10 April 2026, and the register still showed those two at its 23 April 2026 revision	The Hong Kong dollar follows you anywhere: issuing an HKD-referenced stablecoin outside Hong Kong is a regulated activity (section 5); HKD 25 million of paid-up capital, a trust-held reserve at least equal to par, and no passport
United States	The GENIUS Act’s permitted payment stablecoin issuer regime, with OCC and FDIC rules still being written	A statute in force since July 2025 that had produced no final rules at its one-year mark; by 6 October 2026 the Federal Register carried proposed rules from the OCC (2 March), the FDIC (10 April), the NCUA (18 May), Treasury (18 August) and the Federal Reserve (29 September), and one procedural interim final rule on state-certification forms, in effect from 30 September, while every substantive implementing rule was still a proposal; the effective date tracks the 18 January 2027 outer bound	You can structure to qualify; you cannot yet complete the approval the statute promises
UAE	CBUAE for anything dirham-referenced, under the Payment Token Services Regulation; VARA, FSRA or DFSA for the rest	A working framework whose transition period has ended, with the zone regulators handling non-AED tokens	The reference asset decides the regulator before you decide anything else
Singapore	MAS, whose framework would keep issuers to core issuance once enacted; token services are regulated under the Payment Services Act	A narrow lane, set but not yet law, built for containment of issuer risk rather than volume. MAS finalised the single-currency stablecoin framework on 15 August 2023 and consulted on the Payment Services Act amendments to enact it on 1 September 2026, closing 16 October 2026	Business-line restrictions on issuers once enacted, and a hard retail line on the services around them
India	Nobody: there is no issuance regime	No framework, an openly hostile central bank preferring the digital rupee, and punitive VDA taxation: 30 percent on gains and 1 percent TDS under the Income-tax Act 2025, in force since 1 April 2026	Indian teams issue through a foreign issuer and manage the India leg deliberately, including FIU-IND registration

Several of these regimes are mid-rulemaking, and the register figures are dated to the update cited. Confirm every point against current law for your facts before structuring anything.

Hong Kong: the newest live regime

Hong Kong went from statute to licences in a little over eight months. The Stablecoins Ordinance (Cap. 656) took effect on 1 August 2025, and on 10 April 2026 the Monetary Authority granted the first two licences, to Anchorpoint Financial Limited and The Hongkong and Shanghai Banking Corporation Limited, both effective that day. The register the HKMA keeps under section 21 still showed those two at its 23 April 2026 revision. Two licences in eight months, one of them to a bank, tells you the gate is narrow.

The scope is the part founders miss. Under section 5 a person carries on a regulated stablecoin activity by issuing a specified stablecoin in Hong Kong, or by issuing one anywhere in the world that references the Hong Kong dollar wholly or partly, or by doing anything else the Monetary Authority specifies. Doing so without a licence is an offence under section 8. A licensee may offer its stablecoins only through permitted offerors under section 9(2): another licensee, an authorized institution, a stored value facility licensee, an SFC-licensed virtual asset trading platform or a Type 1 licensed corporation. The minimum criteria in Schedule 2 ask for paid-up share capital of at least HKD 25,000,000 or an equivalent the Monetary Authority approves (section 4), a segregated reserve pool for each stablecoin type whose market value is at all times at least the par value in circulation, in high-quality, highly liquid assets held in the same referenced currency unless the Monetary Authority approves otherwise, under a trust arrangement (section 5), and a right to redeem at par that survives the issuer’s insolvency (section 6).

Why Hong Kong, and why not. It fits a token that references the Hong Kong dollar, which the Ordinance catches wherever you issue it, and an issuer that wants a Hong Kong-regulated label for Asia-facing distribution and can fund bank-grade capital and a trust-held reserve. It does not fit a euro token for EU users, because the licence does not passport and MiCA still applies there; it does not fit a dirham token, which belongs to the CBUAE; and a US dollar token aimed at US users still answers to the GENIUS Act once it takes effect. Hong Kong is a destination for a specific token, not a shortcut around the regulator your users already have.

How to issue your own stablecoin: the sequence

Fix the reference currency. It decides the regulator before anything else does: dirham means the CBUAE; Hong Kong dollar means the HKMA wherever you sit; euro for EU users means MiCA’s e-money token track; US dollar for US users means the GENIUS Act once its rules are final.
Map the first serious distribution. Where users and banking sit decides which of the possible regulators is worth the application, and whether more than one is.
Build the issuer the regime names. EU: a credit institution or electronic money institution (MiCA Article 48). Hong Kong: a licensee with HKD 25 million of paid-up capital or an approved equivalent (Schedule 2, section 4). UAE: a UAE company outside the financial free zones whose exclusive business is issuing, with AED 15 million of capital (Articles 6, 13 and 17). US: a subsidiary of an insured depository institution, a federal qualified issuer or a state qualified issuer (section 2).
Design the reserve and redemption to the local rule. A claim at par at any time in the EU (Article 49), with at least 30 percent of the funds received kept in separate credit-institution accounts and the rest in secure, low-risk, highly liquid assets in the same currency (Article 54); a trust-held pool worth at least par in Hong Kong; cash in a segregated escrow account at an unrelated UAE bank, equal to face value in circulation (Article 22); the Section 4(a)(1) asset list at 1 to 1 in the US.
Write the disclosure and the audit calendar. A white paper in the EU and the UAE; a monthly reserve report examined by a registered public accounting firm and certified by the CEO and CFO in the US; the HKMA’s supervisory guideline in Hong Kong.
Drop any plan to pay holders interest. Every regime bans it: MiCA Article 50, GENIUS Act section 4(a)(11), CBUAE Article 12(3), and MAS’s 1 September 2026 consultation carries the same prohibition.
Structure the group, then file. The issuer, the technology company and the treasury each sit where their own rules are satisfied, which for corridor businesses usually means more than one of these markets at once. The engagement that runs this is on stablecoin issuance advisory.

The question behind the question

Founders ask where issuance gets approved fastest. The better question is what the approval buys. An EU authorisation passports a compliant EMT across the single market, at the price of e-money discipline and a statutory ban on paying holders interest. A UAE authorisation gives you a regulator built for the asset class, at the price of choosing your reference asset first, because which UAE door you use depends on it. A US position today is a bet on the final rules, and so is a Singapore one, because MAS is still writing its stablecoin framework into law. The choice is a market-access decision wearing a regulatory costume.

The pattern we see work: decide the reference currency, map where the first serious distribution actually happens, and let those two facts pick the regulator. Then structure the group so the issuer, the technology company and the treasury each sit where their own rules are satisfied, which for corridor businesses usually means more than one of these markets at once. That structuring layer is the work; the application is its output. Under MiCA, an asset-referenced token issuer must also give its competent authority a legal opinion that the token is neither an excluded crypto-asset nor an e-money token (Articles 17(1)(b)(ii) and 18(2)(e)); which regulators require a token legal opinion, and who signs each, is set out separately. If the EU is in the plan, the MiCA programme is how we run it.

On the US leg, one more moving part: the SEC’s proposed Regulation Crypto Assets of 18 August 2026 would set the securities-law perimeter around tokens generally, while the GENIUS Act, once effective, takes a permitted issuer’s payment stablecoin out of the definition of security. Our comment letter on the proposal is at SEC Regulation Crypto Assets: comment letter.

What moved between 2 September and 6 October 2026

ESMA’s MiCA register, updated 30 September 2026, lists 25 e-money token issuers on 50 register lines across 13 member states and Iceland, up from 21 issuers in 12 member states at the 31 July update; the asset-referenced token register is still empty.
Hong Kong’s first two stablecoin issuer licences took effect on 10 April 2026 and are the only entries on the HKMA register as revised 23 April 2026; the regime page was last revised 13 July 2026.
The US produced proposals for every substantive rule: Treasury’s 18 August 2026 proposal on who may issue, offer or sell (comments to 19 October 2026) and the Federal Reserve’s 29 September 2026 proposal (comments to 30 November 2026). The only rule in effect is Treasury’s 30 September 2026 interim final rule on state-certification forms, a procedural rule effective that day.
MAS opened consultation on 1 September 2026 on the Payment Services Act amendments that would finally enact its 2023 single-currency stablecoin framework, including a ban on paying interest; it closes 16 October 2026.

Frequently asked questions

Where is it easiest to get a stablecoin issuance approved?

Easiest is the wrong test, because the markets differ in what approval buys you. The EU is the only regime today with a live, passportable issuance track, and ESMA's register listed 25 e-money token issuers at its 30 September 2026 update. Hong Kong granted its first two licences on 10 April 2026, to Anchorpoint Financial Limited and The Hongkong and Shanghai Banking Corporation Limited, but the licence does not travel. The UAE offers a working path with a hard fork: dirham-referenced tokens belong to the Central Bank, everything else to the virtual-asset regulators. The US has a statute but is still writing the rules, Singapore is still legislating its stablecoin framework, and India has no issuance regime at all. Pick by where your users and banking sit, not by perceived speed.

Can you issue a stablecoin in the US under the GENIUS Act today?

The statute is law and it bans issuers from paying yield, but at the one-year mark it had produced no final implementing rules, and the effective date tracks the outer statutory bound in early 2027. Practically, the US is a positioning environment right now: structure so you qualify as a permitted issuer when the rules land, rather than expecting a completed approval today. On the Federal Register as at 6 October 2026 the implementing work was still proposals: the OCC's rule of 2 March 2026, the FDIC's of 10 April, the NCUA's of 18 May, Treasury's of 18 August on who may issue, offer or sell, and the Federal Reserve's of 29 September, with comments on the last open until 30 November 2026. The only rule in effect was Treasury's interim final rule of 30 September 2026 on state-certification forms; every substantive implementing rule was still a proposal. Section 20 sets the effective date at the earlier of 18 months after the 18 July 2025 enactment, which is 18 January 2027, or 120 days after the final regulations.

What is the difference between an EMT and an ART under MiCA?

An e-money token references one official currency and is the track real issuers actually use; an asset-referenced token references a basket or other assets. The register tells the story: as of ESMA's 31 July update there were 21 EMT issuers with 41 approved white papers across 12 member states, and zero ART issuers anywhere in the EU. If you are issuing a fiat-backed stablecoin for the EU market, you are in practice choosing the EMT track and the e-money discipline that comes with it. The register's 30 September 2026 update lists 25 EMT issuers on 50 register lines across 13 member states and Iceland, and the ART column is still empty.

Who regulates a dirham-backed stablecoin in the UAE?

The Central Bank of the UAE, exclusively, under the Payment Token Services Regulation (Circular 2/2024), in force since 31 August 2024 with a one-calendar-year transition period under Article 40 that the Central Bank could extend at its discretion. The zone regulators do not share this territory: anything referenced to the dirham is CBUAE business regardless of where the issuer sits, while non-AED tokens fall to VARA in Dubai outside the DIFC, the FSRA in ADGM, or the DFSA in the DIFC.

Can you issue a stablecoin from India?

There is no Indian framework for it. India has no stablecoin issuance regime, the RBI has been openly hostile to private stablecoins while promoting the digital rupee, and the tax code treats VDA income punitively. Indian teams that want to issue do it through a foreign issuer in a regulated market and handle the India leg, the FIU-IND perimeter, founder equity under FEMA, and the related-party file, deliberately.

Is a stablecoin legal in India?

No Indian law or regulation creates a stablecoin issuance licence, so issuing one under an Indian licence is not possible. None we have verified prohibits holding or trading one; verify the RBI position before relying on this. A stablecoin is a virtual digital asset under section 2(111) of the Income-tax Act 2025, in force since 1 April 2026: gains are taxed at 30 percent under section 194(1) Table Sl. 4, and 1 percent TDS is deducted on transfers under section 393(1) Table Sl. 8(vi). Any business that exchanges, transfers or holds stablecoins for Indian users sits inside the FIU-IND reporting perimeter. FIU-IND updated its guidelines on 8 January 2026, and its Director issued section 13 notices to fifteen offshore VDA service providers on 9 September 2026 (PIB Release ID 2308131). The issuer itself sits abroad in one of the markets above, and the India work is the FIU-IND file, FEMA on the founders' holdings and the related-party agreements with the Indian technology company.

What does the CBUAE Payment Token Services Regulation require of a dirham stablecoin issuer?

A company incorporated in the UAE, in a free zone if you like but not in the ADGM or DIFC financial free zones, whose exclusive business is issuing (Articles 6(2) and 17). Initial and ongoing capital of at least AED 15 million plus 0.5 percent of the face value of tokens outstanding (Article 13). A reserve held as cash in a separate escrow account at an unrelated UAE-licensed bank, in the same currency as the tokens, worth at all times at least the face value of tokens in circulation; a bank's wholly owned subsidiary may instead keep 50 percent in cash and the rest in UAE government bonds and Central Bank M-bills averaging six months or less, at 2 percent additional capital (Articles 22 and 13(2)). A licensed issuer may issue dirham tokens only to persons resident in the UAE, though the Regulation places no other territorial limit on where the tokens are used or transferred, and no interest or other time-based benefit may be paid to holders (Articles 2(6) and 12(3)). A foreign-currency token takes the registration route under Article 9 instead, which needs a legal opinion on every token (Article 9(4)), and UAE merchants may accept it only in payment for virtual assets or their derivatives (Article 2(7)).

What are the GENIUS Act stablecoin reserve requirements?

Section 4(a)(1) of the GENIUS Act (Public Law 119-27, enacted 18 July 2025) requires a permitted payment stablecoin issuer to hold identifiable reserves of at least 1 to 1 against outstanding tokens, made up only of US coins and currency and Federal Reserve balances, demand deposits or insured shares at depository institutions, Treasury bills, notes or bonds with 93 days or less to run, overnight repos and reverse repos on those Treasuries, government money market funds invested in the same assets, and any other federal-government asset the regulators approve. The reserve may not be pledged, rehypothecated or reused except for narrow margin, custody and Treasury repo purposes (Section 4(a)(2)). The issuer publishes a monthly reserve composition report examined by a registered public accounting firm, and the CEO and CFO certify it each month (Sections 4(a)(1)(C) and 4(a)(3)). Section 4(a)(11) bans paying holders any interest or yield for holding the token. The rules that give these words their detail were still proposals on 6 October 2026.

How do you issue your own stablecoin?

Fix the reference currency, then let it and your first users pick the regulator: euro and EU users point at an e-money token under MiCA, Hong Kong dollars or Asia-facing distribution at a Hong Kong licence, dirhams at the CBUAE, US dollars for US users at a permitted issuer once the GENIUS rules are final. Build the issuer that regime names: an EU credit institution or electronic money institution, a Hong Kong licensee with HKD 25 million of paid-up capital, a UAE company with AED 15 million whose only business is issuing, or one of the three US permitted issuer types. Design the reserve to that regime's rule, the redemption at par, the disclosure document and the audit calendar, and accept that none of them lets you pay holders interest. Then structure the group around the issuer and file. The sequence is set out on this page; the engagement that runs it is the stablecoin issuance advisory.

Stablecoin licence: Hong Kong vs UAE vs EU, which fits which issuer?

The EU fits an issuer that needs one authorisation to serve the whole single market and can live with e-money discipline: 25 EMT issuers were on ESMA's register at its 30 September 2026 update. Hong Kong fits an issuer whose token references the Hong Kong dollar, or whose distribution is Asia-facing, and who can fund HKD 25 million of capital and a trust-held reserve; two licences existed at the register's 23 April 2026 revision and the licence does not travel beyond Hong Kong. The UAE fits a dirham token licensed by the Central Bank, or a foreign-currency token registered with it, while VARA, the FSRA and the DFSA handle tokens that reference anything else. Pick by reference currency and by where the first serious volume sits, not by which regulator sounds quickest.

Launching a stablecoin in 2026, do issuers need 1 to 1 reserves and a licence?

In every regulated market, yes to both, and a token backed 1 to 1 without a licence is still an unlicensed token. The EU admits only an authorised credit institution or electronic money institution as an e-money token issuer and gives holders a claim at par at any time, with at least 30 percent of the funds received kept in separate credit-institution accounts (MiCA Articles 48, 49 and 54). Hong Kong makes issuing a specified stablecoin without a licence an offence under section 8 of the Stablecoins Ordinance and requires a trust-held reserve of high-quality, liquid assets worth at all times at least the par value in circulation (Schedule 2). The UAE requires a CBUAE licence for a dirham token and a cash reserve at least equal to the face value of tokens in circulation (Article 22). The US statute requires 1 to 1 identifiable reserves and a permitted issuer approval, with the section 3 ban on anyone else issuing biting from the effective date. Singapore's single-currency stablecoin rules were still being legislated at 1 September 2026, so there is no MAS-regulated stablecoin label to earn yet, and India has no licence to apply for.

Next step

Deciding where a stablecoin should issue from?

Tell us the reference currency, where your users sit, and where your banking is. We will map which regulator that combination actually points at, and the structure that survives all of them, before you commit to a jurisdiction.

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