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Comparison of Stablecoin Regulatory Frameworks in the EU, UAE, and Singapore: Entry Barriers, Reserve Management, and Compliance Requirements
Comparative Analysis of Stablecoin Regulatory Frameworks: EU, UAE, and Singapore
In recent years, with the rapid development of the cryptocurrency industry, stablecoins have received significant attention from regulatory agencies in various countries as an important type of crypto asset. This article will conduct a comparative analysis of the stablecoin regulatory frameworks in the EU, UAE, and Singapore, aiming to provide readers with a comprehensive perspective.
I. European Union
1. Regulatory processes and normative documents
The European Union officially released the "Regulation on Markets in Crypto-Assets" (MiCA) on June 2023, (, aiming to establish a unified regulatory framework for crypto assets. The rules regarding the issuance of stablecoins in this regulation will come into effect on June 30, 2024.
) 2. Regulatory authorities
The European Banking Authority ### EBA ( and the European Securities and Markets Authority ) ESMA ( are responsible for establishing the regulatory framework and supervising significant stablecoin issuers and related service providers. National competent authorities also possess some regulatory powers.
) 3. Main contents of the regulatory framework
a. Definition of stablecoin
The MiCA regulation divides stablecoins into two categories:
Algorithmic stablecoins are not included in the regulatory framework, which effectively means they are banned.
![Web3 Lawyer's In-depth Interpretation: A Detailed Explanation of the Stablecoin Regulatory Frameworks in the EU, UAE, and Singapore])https://img-cdn.gateio.im/webp-social/moments-769852fe8ac92ba2fdb2b4acc6ff84c8.webp(
)# b. Admission threshold for issuers
There are two types of ART issuers:
MiCA adopts a tiered regulatory model, setting different access thresholds and regulatory requirements based on the average circulation value of ART.
c. Stablecoin value stabilization mechanism and maintenance of reserve assets
d. Compliance requirements for circulation.
e. Important special regulatory rules for ART
ART that meets specific criteria is classified as important ART, and its issuer must undertake additional obligations.
![Web3 Lawyer's In-Depth Analysis: A Comprehensive Explanation of the Stablecoin Regulatory Frameworks in the EU, UAE, and Singapore]###https://img-cdn.gateio.im/webp-social/moments-6d7dd20653dfdc9b404568bbed49dd3e.webp(
2. United Arab Emirates
) 1. Regulatory processes and normative documents
In June 2024, the Central Bank of the UAE issued the "Payment Token Service Regulations", clarifying the definition and regulatory framework of "payment tokens" ### stablecoin (.
) 2. Regulatory authorities
The UAE adopts a "federal-Emirate" dual-track parallel regulatory system. The UAE Central Bank is responsible for regulation at the federal level, but this does not include the two financial free zones, DIFC and ADGM.
3. Main content of the regulatory framework
a. Definition of stablecoin
The regulation defines stablecoin as: "A virtual asset intended to maintain a stable value by referencing the value of a fiat currency or another stablecoin priced in the same currency."
b. Issuer's access threshold
Applicants must meet the legal form requirements, initial capital requirements, and provide necessary information and documents.
c. The mechanism for stabilizing coin value and maintaining reserve assets
![Web3 Lawyer's In-Depth Interpretation: A Detailed Explanation of the Stablecoin Regulatory Frameworks in the EU, UAE, and Singapore]###https://img-cdn.gateio.im/webp-social/moments-3bf079973b0c20054195ec2384c4950c.webp(
)# d. Compliance requirements in the circulation process
![Web3 Lawyer's In-Depth Interpretation: A Detailed Explanation of the Stablecoin Regulatory Framework in the EU, UAE, and Singapore]###https://img-cdn.gateio.im/webp-social/moments-aad0466a5462ba27e39e72d7aa4c6712.webp(
3. Singapore
) 1. Regulatory processes and normative documents
2. Regulatory authorities
The Monetary Authority of Singapore ### MAS ( is responsible for regulation.
) 3. Main contents of the regulatory framework
a. Definition of stablecoin
The "Stablecoin Regulatory Framework" only regulates single-currency stablecoins issued in Singapore that are pegged to the Singapore dollar or G10 currencies.
b. Admission threshold for issuers
Applicants must meet the basic capital requirements, business restriction requirements, and solvency requirements.
c. Stablecoin value stabilization mechanism and maintenance of reserve assets
d. Compliance requirements in the circulation link
The issuer must fulfill the statutory redemption obligation, redeeming the holder's stablecoin at face value within five working days.
![Web3 Lawyer's In-depth Interpretation: A Detailed Explanation of the Stablecoin Regulatory Framework in the EU, UAE, and Singapore]###https://img-cdn.gateio.im/webp-social/moments-db63f39087c24a76f86f58a0b938487d.webp(