Comparison
GENIUS Act vs. MiCA
The two most comprehensive stablecoin frameworks in force today — one federal, one supranational. Compared provision by provision.
Aspect
GENIUS Act
MiCA
Effective
July 18, 2025
June 30, 2024
Scope
Payment stablecoins only
All crypto-assets (stablecoins = EMTs + ARTs)
Issuer requirement
OCC charter (>$10B) or state MTL (<$10B)
EMI or credit institution authorization
Reserve assets
T-bills ≤93 days, FDIC deposits, govt MMFs, repos
Bank deposits (≥30%), govt bonds ≤5yr
Reserve segregation
Required, held at qualified custodians
Required, ≥3 credit institutions for deposits
Attestation
Monthly (CPA), annual audit >$50B
Quarterly disclosure, annual audit
Redemption
At par, within 1 business day
At par, per white paper timeline
Securities status
Explicitly NOT a security
Not classified as MiFID financial instrument
Travel Rule threshold
$3,000
€0 (no minimum)
AML framework
BSA / FinCEN
AMLD5/6 / TFR
Significant thresholds
$10B (federal oversight)
€5B issuance, 10M holders, €500M/day volume
Passporting
N/A (single jurisdiction)
Yes — 27 member states + EEA
Analysis
What the differences mean
The big picture: Both frameworks require 1:1 reserves and at-par redemption, but they diverge sharply on scope, supervisory architecture, and AML thresholds.
- Scope gap. The GENIUS Act covers payment stablecoins only. MiCA regulates the entire crypto-asset spectrum — stablecoins are a subset, split into EMTs and ARTs with different rules for each.
- Dual vs. single passport. The U.S. uses a dual federal-state model with no cross-border passporting. MiCA grants a single authorization valid across 27 member states and the EEA — one license, continent-wide distribution.
- Travel Rule exposure. MiCA applies the Travel Rule at zero threshold — every transfer carries originator and beneficiary data. The GENIUS Act sets the floor at $3,000, consistent with existing BSA requirements.
- Reserve composition. U.S. reserves skew toward ultra-short Treasuries (93-day max). EU reserves require at least 30% in bank deposits spread across three or more credit institutions — a liquidity buffer designed for rapid redemption.
- Significance triggers. The $10B federal oversight threshold in the U.S. is a single metric. MiCA uses three independent triggers — issuance volume, holder count, and daily transaction volume — any one of which can elevate an issuer to "significant" status.
The bottom line: Issuers operating in both jurisdictions face overlapping but non-identical compliance obligations. The strictest requirement from either framework becomes the effective floor.
Jurisdiction Deep Dives