The Bank for International Settlements Financial Stability Institute has published a comparative analysis of stablecoin issuance frameworks in the European Union, Hong Kong, Singapore, the United Kingdom and the United States. The review finds broad agreement that issuance, redemption and reserve management are issuers’ core functions, but substantial differences in eligible entities, licensing structures and permitted activities such as lending, staking, proprietary trading and third-party custody. Banks generally may conduct a broader range of activities because existing prudential regimes address the associated risks, while bespoke regimes for non-bank issuers apply stricter or conditional limits. However, these restrictions generally apply only to the issuing entity. Unlike banking groups subject to consolidated supervision, non-bank groups can relocate restricted activities to affiliates, prompting the brief to suggest group-level oversight for larger non-bank issuers unless proportionate measures effectively address contagion, conflicts of interest and risks to stablecoin holders.
2026-08-27Bank for International Settlements - Financial Stability Institute
Bank for International Settlements Financial Stability Institute identifies non-bank group oversight gaps in stablecoin regimes
The Bank for International Settlements Financial Stability Institute finds major differences across five stablecoin regimes in eligible issuers and permitted non-core activities. It highlights a group-level oversight gap for non-bank issuers, whose affiliates may conduct activities prohibited to the issuing entity.