Stablecoin regulation, regime by regime
Who supervises each dollar token, what the rules require, and — just as important — what they leave uncovered. Every row links to the tokens issued under that regime.
No prudential regime
NoneWhatever the issuer or protocol chooses to hold. For crypto-collateralised tokens this is enforced by code and over-collateralisation rather than by law.
VARA-regulated (Dubai)
Dubai, UAEFull reserve backing with segregation and periodic independent verification.
MiCA e-money token
European Union / EEAFull backing, segregated from the issuer's own assets, with at least 30% of fiat reserves held as deposits at EU credit institutions (60% for significant tokens) and the rest in low-risk, highly liquid instruments.
GENIUS-covered
United States (federal)One-to-one backing in cash, insured deposits, short-dated Treasury bills, overnight repo and government money-market funds. Rehypothecation of reserves is restricted.
NYDFS-regulated
New York State, USAFully backed by US Treasury bills with a short maturity, reverse repo and deposits, held separately from corporate assets and attested monthly by an independent CPA.
MAS-regulated (Singapore)
SingaporeReserves in cash, cash equivalents or short-dated sovereign debt, held with a minimum 100% backing and independent monthly attestation.
Regimes at a glance
| Regime | Regulator | Redemption right | Disclosure |
|---|---|---|---|
| MiCA e-money token | National competent authorities under ESMA and EBA coordination | A legal right to redeem at par, at any time, free of charge, enforceable against the authorised issuer. | Published white paper, ongoing reserve reporting, and notification duties to the home regulator. |
| GENIUS-covered | Federal banking regulators with state pathways for smaller issuers | Issuers must publish redemption policy and honour redemption at par; holders rank ahead of other creditors in insolvency. | Monthly reserve composition reports, examined by a registered accounting firm. |
| NYDFS-regulated | New York State Department of Financial Services | Redemption at par no later than two business days after a conforming request. | Monthly attestation published by an independent auditor under AICPA standards. |
| MAS-regulated (Singapore) | Monetary Authority of Singapore | Redemption at par within five business days of request. | Monthly attestations plus an annual audit of the reserve fund. |
| VARA-regulated (Dubai) | Virtual Assets Regulatory Authority | Redemption terms set in the issuer's approved rulebook filing. | Periodic reporting to VARA; public disclosure varies by issuer. |
| No prudential regime | No prudential supervisor | None in law. Redemption depends on the issuer's own policy, or on protocol mechanics for decentralised tokens. | Voluntary. Quality ranges from real-time on-chain proof to nothing at all. |
Frequently asked
+ − Does 'regulated' mean a stablecoin is safe?
It means someone supervises the issuer's reserves and redemption. It does not cover exchange failure, smart-contract bugs, or the price you get on a secondary market during stress.
+ − Which regime is the strictest?
MiCA and the NYDFS trust framework are the most prescriptive on reserve composition and redemption timing. The GENIUS Act sets a comparable federal US bar and adds creditor priority for holders.
+ − Can one stablecoin sit under two regimes?
Yes. USDC is issued by an EU e-money institution for EEA users and under US supervision domestically, so the same ticker can be covered by different rules depending on where it was issued.
Looking for the lists? MiCA-compliant stablecoins · GENIUS Act-aligned stablecoins