The US moved first. President Biden signed the GENIUS Act into law on July 18, 2025, giving the country its first federal framework specifically designed for payment stablecoins. The UK followed with its own set of moves in mid-2026, with the Bank of England publishing a detailed policy statement on June 22 and the Financial Conduct Authority finalizing its crypto asset regime rules on June 30.

What the rules actually say

The GENIUS Act is built around one core principle: if you issue a stablecoin in the US, it needs to be backed one-to-one by US dollars or similarly low-risk assets. There’s a notable restriction baked into the law. Issuers are prohibited from paying interest or yield to stablecoin holders. It draws a hard line between stablecoins as payment instruments and stablecoins as investment products, keeping them firmly in the former category. Full implementing rules are expected by mid-2026, with enforcement kicking in from January 2027.

The UK’s approach layers in more nuance. The BoE and FCA framework distinguishes between systemic issuers, those large enough to pose risks to financial stability, and non-systemic issuers. Systemic issuers fall under dual oversight from both the BoE and FCA. Non-systemic issuers deal primarily with the FCA. Both categories face strict requirements around backing assets and redemption rights, but the prudential oversight is proportionally heavier for the big players. The application gateway for the new UK regime is targeted to open in late 2026, with the full framework taking effect in 2027.