Stablecoins just got rulebooks in the US, EU and UK at once

A stablecoin is a digital token designed to always be worth exactly one dollar, one euro or one pound. For most of their short history, stablecoins have lived in a strange place: used to move hundreds of billions of dollars, but without clear rules about who may issue them, what must back them, or what happens if holders all want their money back at once.

That changed remarkably quickly this autumn. Within a few weeks, regulators in the United States, the European Union and the United Kingdom all took concrete steps. Each made different choices, and banks have started moving in from several directions at once.

This is a Foreshock story because most people will not notice any of it yet. Real everyday payments with stablecoins are still a small slice of the total. But when the rules, the licences and the big banks all arrive in the same season, the shape of the next decade of payments is being set.

The United States: a licence with a hard deadline

The US now has a federal stablecoin law, known as the GENIUS Act. This year the regulators started filling in the details.

On October 21, the Office of the Comptroller of the Currency (OCC), which supervises national banks, issued the first final rule under the Act. It takes effect on January 18, 2027, the same day as the law itself. According to the law firm WilmerHale, the final rule is noticeably softer than the March draft:

• the minimum share of reserves that must be available daily was cut from 10% to 5%;
• several other liquidity and maturity limits were dropped;
• issuers must still pay holders back within two business days, but instead of an automatic seven-day extension in a crunch, they must notify the OCC when redemptions exceed 10% of their tokens in a day;
• stress testing and reserve buffers were added.

One detail creates real urgency: existing issuers are not "grandfathered". Every issuer needs to apply under the new regime. Waivers of up to a year exist only for applications already pending on January 18, 2027, and as of late October the application form itself had not been published. The US central bank, the Federal Reserve, proposed its own rules in September, and comments are open until November 30, 2026.

The European Union: pushing unlicensed coins off the shelves

Europe took a different route. Its crypto law, MiCA, already requires stablecoin issuers to be authorised. The new step is about where those coins can be traded.

On October 8, the EU's securities markets authority, ESMA, published an opinion telling crypto platforms licensed under MiCA to stop offering services in stablecoins whose issuers are not authorised in the EU. Platforms have about three months, to roughly January 8, 2027, to wind down, with only limited services such as conversion and withdrawal allowed in the meantime. Trade press names USDT, the world's largest stablecoin, as the main token affected, while Circle's USDC and EURC are authorised.

Instead of banning anything outright, the EU is using access to its market as the lever. That favours issuers who have done the licensing work, and it creates a window in which European platforms need to switch their liquidity. One risk is that some users simply move to offshore exchanges instead.

Europe's banks build their own euro coin

The most striking European signal is Qivalis, a company in Amsterdam set up in September 2025 by a group of banks to issue a euro stablecoin. In May 2026 it grew from 12 to 37 member banks in 15 countries, including ABN AMRO, Rabobank, Nordea, Intesa Sanpaolo, BPCE, Erste Group, Bank Pekao and Raiffeisen Bank International.

Around October 14, Qivalis received authorisation as an electronic money institution from De Nederlandsche Bank, the Dutch central bank. It still has to meet the remaining MiCA requirements and publish a white paper before issuing tokens, which it now expects "in the coming months".

Two numbers explain why European banks care. According to Qivalis, euro-denominated tokens are only about 0.2% of global stablecoin circulation; almost everything is in dollars. And total stablecoin supply is about $288 billion, according to the data site rwa.xyz at the end of October. If digital money becomes a mainstream way to settle payments, Europe's banks do not want it to be almost entirely dollar-based.

The challenge is distribution. Qivalis sells through banks, exchanges and payment firms rather than directly to the public, so each member bank still has to build it into its own apps and systems before ordinary customers see it.

The United Kingdom: stablecoins for everyday payments, on thin margins

In June, the Bank of England published its final approach to "systemic" sterling stablecoins, meaning ones big enough to matter for the financial system. Its earlier proposal had capped how much any one person could hold, at £20,000. The final version drops individual limits and instead caps total issuance, initially at £40 billion per stablecoin.

That makes sterling stablecoins far more practical for everyday payments. But the backing rules keep margins thin. In steady state, 70% of reserves can sit in short-dated government bonds, but 30% must be held as deposits at the Bank of England that earn no interest. That favours issuers with other income, such as banks and large fintechs. The Financial Conduct Authority published its own final crypto rules at the end of June, including a requirement to pay holders back at face value by the end of the next business day.

The banks' other route: deposit tokens

Not every bank wants a stablecoin. Some are turning ordinary deposits into tokens instead.

On October 19, JPMorgan's blockchain unit Kinexys brought its dollar deposit token, JPMD, to Ethereum's main network for institutional clients, after launching on Base in November 2025. JPMorgan says Kinexys has processed more than $4 trillion in total, about $7 billion a day. In the US, five regional banks announced in February a shared tokenised deposit network with a company called Cari, aiming for customer availability in the fourth quarter of 2026.

Meanwhile the European Central Bank switched on Pontes on September 21. It connects blockchain-based trading platforms to the ECB's existing payment system, so banks can settle tokenised trades in central-bank money. A retail digital euro, by contrast, is still in negotiation between EU institutions, with a pilot planned for 2027 and possible issuance around 2029.

So there are now three kinds of digital money for big transactions: private stablecoins, bank deposit tokens and central-bank settlement. Each works on its own. What is still missing is the bridge between them, a way to move value smoothly from one bank's token to another's, or from a deposit token to a stablecoin.

How much is this actually used?

Less than the headlines suggest. McKinsey and Artemis estimated that stablecoins moved more than $35 trillion on blockchains in 2025, but only about $380–390 billion of that, roughly 1%, was real-world payments. Most of it was business-to-business transfers, followed by payroll and money sent home by migrant workers. The rest is trading and internal transfers.

There are fast-growing pockets. Visa reported in September that its stablecoin settlement was running above $20 billion a year, up more than fifteen-fold year on year. New money is flowing into payment companies that use stablecoins behind the scenes, such as PhotonPay, which raised $40 million at the end of October, and Noah, with $38 million in total funding.

A note for Hungary

Hungary had an unusual year. A domestic rule requiring an extra validation step, which took effect in July 2025, led Revolut, eToro and others to restrict crypto services for Hungarian customers. In July 2026 the central bank, the MNB, granted its first licence under MiCA to a Hungarian-headquartered firm, CoinCash, and parliament voted to remove the extra requirement. Hungary is returning to the standard European regime. No Hungarian bank is listed among Qivalis's members.

What could go wrong with this story

• Payments may stay a sideshow. At about 1% of flows, real-world use could grow slowly regardless of the rules.
• Supply isn't only going up. Total stablecoin supply dipped about 2% over the 30 days to late October.
• A euro licence doesn't guarantee demand against the deep liquidity of dollar coins.
• Europe's market-access push could drive users offshore rather than towards authorised coins.
• US timelines could slip. Several pieces, including the Fed's final rule and rules for foreign issuers, are still open.

What to watch next

• November 30, 2026: comments close on the Federal Reserve's stablecoin proposals.
• Around January 8, 2027: the end of ESMA's three-month wind-down window for unauthorised stablecoins on EU platforms.
• January 18, 2027: the US stablecoin law and the OCC rule take effect, with no grandfathering.
• Qivalis's white paper and first issuance, and which banks build it into their apps first.
• The first bridge between deposit tokens and stablecoins across different banks, the missing piece in the new system.

The rules for digital money used to be a question for crypto enthusiasts. This autumn they became a question for central banks and the largest banks in Europe and America, which is usually the moment a technology stops being an experiment.