Banco de España compares US, UK and EU stablecoin regimes and flags arbitrage gaps

Banco de España staff set three stablecoin frameworks side by side: the EU's MiCAR, already in force; the US GENIUS Act, signed in July 2025 but not operative until 2027; and the UK's phased proposal due by end-2026. The piece dissects redemption rights, reserve composition, capital and crisis management, and explains why co-issuer structures such as Circle's split between its US parent and French subsidiary worry European authorities.

• MiCAR has applied to e-money tokens since June 2024, while the GENIUS Act is not expected to enter force until 2027 with a three-year transition, and the UK framework is due for approval by end-2026.
• MiCAR requires non-bank EMT issuers to hold minimum capital of €350,000 and own funds of 2% of average circulation, rising to 3% for significant issuers, with possible supervisory add-ons of 20% to 40%.
• MiCAR mandates at least 30% of the reserve in same-currency bank deposits, rising to 60% for significant e-money tokens.
• The ESRB published a Recommendation in September 2025 to prohibit multi-jurisdiction co-issuance schemes in Europe absent adequate safeguards, citing the disparity between Circle's US parent and its French subsidiary.
• USDT and USDC account for roughly 90% of global stablecoin volume, at capitalisations of around $190 billion and $80 billion respectively.

Executive summary

The article, published in the Banco de España Financial Stability Review (Issue 50, Spring 2026) and written in the authors' own name, compares the stablecoin frameworks of the EU, the US and the UK against the FSB's high-level recommendations and…

Machine-verified against the primary source, then read, edited and published by the Regulus editorial desk on 19 Oct 2026.