Comparison Tool
Compare stablecoin regimes side by side
The bottom line: Select two to four jurisdictions below to compare their stablecoin regulatory frameworks across 16 dimensions — from reserve composition and redemption timelines to Travel Rule thresholds and passporting rights. All data sourced from primary legislation and regulatory authority publications.
Select jurisdictions to compare (up to 4)
| Dimension | United States | European Union |
|---|---|---|
| Regime Status | Comprehensive | Comprehensive |
| Legislation | GENIUS Act | MiCA (Regulation 2023/1114) |
| Effective Date | 2025-07-18 | 2024-06-30 |
| Scope | Payment stablecoins only | All crypto-assets (EMTs + ARTs + other) |
| Primary License | OCC charter (>$10B) or state MTL (<$10B) | EMI authorization or CRD credit institution |
| License Cost | $1M+ (NY BitLicense); $50K–$500K (state MTL) | €350K minimum own funds (EMI) |
| Reserve Requirement | 1:1 backing required | 1:1 backing required |
| Reserve Assets | T-bills ≤93 days, FDIC insured deposits, govt MMFs, Fed reverse repos | Bank deposits (≥30%, ≥3 institutions), govt bonds ≤5yr, covered bonds |
| Redemption | At par, within 1 business day | At par, per white paper terms |
| Attestation | Monthly (CPA), annual audit >$50B | Quarterly disclosure, annual audit |
| Travel Rule | Enforced | Enforced |
| Travel Rule Threshold | $3,000 | €0 (all transactions) |
| AML Framework | BSA / FinCEN | AMLD6 / TFR |
| Passporting | No (state-by-state + federal) | Yes — 27 member states + EEA |
| Significance Threshold | $10B issuance → federal oversight | €5B issuance, 10M holders, or €500M/day volume |
| Supervisory Authority | OCC · FinCEN · SEC | EBA · NCAs (27 member states) |
How to Use
Reading the comparison
Select jurisdictions. Click the buttons above the table to add or remove jurisdictions. You can compare up to four at once. The table updates instantly — no page reload needed.
Find the strictest rule. For cross-border issuers, the most restrictive requirement from any jurisdiction you operate in becomes the effective floor. Compare Travel Rule thresholds, reserve asset restrictions, and redemption timelines to identify where your compliance burden is highest.
Watch for "In Progress" entries. Jurisdictions with pending legislation (UK, Brazil) show proposed rules where available. These may change before enactment. Check the jurisdiction detail pages for the latest consultation status.
Go deeper. Click any jurisdiction name in the table header to visit its full deep-dive page. For the US vs. EU specifically, see the dedicated GENIUS Act vs. MiCA comparison with detailed analysis.
Sources: GENIUS Act (US), MiCA Regulation (EU) 2023/1114, FCA CP24/15 (UK), MAS Payment Services Act + Stablecoin Framework (SG), HKMA Stablecoins Ordinance (HK), VARA/FSMR regulations (UAE), JFSA PSA Amendment (JP), BCB Consultation No. 109/2024 (BR). Updated quarterly.