A stablecoin issuer licence should be chosen as an entity and activity decision, not only a token decision. A Financial Stability Institute study published on 27 August compares five frameworks, using information current to July 2026, and finds materially different entry routes across the EU, Hong Kong, Singapore, the UK and the US.
The legal baselines are uneven: EU and Hong Kong rules are in force, while the UK and US paths are moving towards implementation and Singapore has promised further clarification.
For founders and compliance leads, the practical message is to settle the issuing entity, planned adjacent services and group structure before choosing a jurisdiction. A model that combines issuance with lending, staking, proprietary trading or custody may need a separate permission, a separate entity or a different market altogether.
Which stablecoin issuer licence fits the business model?
The five frameworks do not use one common gateway. In the EU, a non-bank issuer of an e-money token must be authorised as an electronic money institution, while a credit institution can issue under its banking authorisation after completing the MiCA notification requirements. Singapore also places non-bank issuers on a payments-licensing route, although the BIS notes that MAS is reviewing parts of its announced framework.
Hong Kong, the UK and the US instead require a stablecoin-specific licence or authorisation for non-bank issuers. The UK framework also requires an issuer to operate through a UK legal entity. That means the useful comparison is not just the global crypto licensing matrix, but also whether an e-money route or a dedicated issuer vehicle better matches the product.
Bank and non-bank routes diverge
Bank ownership does not remove the structure question. The BIS comparison says banks may issue directly from the deposit-taking entity in the EU and Hong Kong, subject to the applicable requirements. UK deposit-taking institutions and US insured depository institutions must use a subsidiary for stablecoin issuance.
Foreign incorporation is another early filter. Most of the five frameworks require a local legal entity. Hong Kong provides a narrow exception for a foreign bank with a local branch, but it still needs a stablecoin licence and must satisfy both banking and issuer criteria. Founders comparing the UK crypto licence profile with the Hong Kong crypto licence profile should therefore map the proposed issuer, branch and operating companies before comparing application processes.
Activity permissions can force another authorisation
All five frameworks recognise issuance, redemption and reserve management as core issuer functions. They separate sharply beyond that core. Singapore and the US use restrictive models for non-bank issuers, limiting or excluding activities such as lending, staking, proprietary trading and third-party crypto custody. The EU, Hong Kong and the UK use constrained models, where those services may be possible through regulatory consent, another licence or another sectoral regime.
In the UK, lending, staking, proprietary trading and safeguarding are separate regulated cryptoasset activities. In the EU, a bank may rely on its wider prudential permissions for some activities, while an electronic money institution remains within the narrower e-money framework. A business plan that treats these services as later add-ons can therefore produce the wrong authorisation scope from day one.
Licence planning should start at group level
The BIS also highlights a structural gap: many activity restrictions bind the issuer, not every affiliate. Bank groups already face consolidated prudential supervision, while non-bank groups may not have an equivalent group-wide framework. Regulators may respond by extending oversight or demanding stronger safeguards where risk sits elsewhere in the group.
The immediate task is to draw the legal-entity map alongside the product map, then test every planned service against the chosen framework. The licence label is only the start; the permitted business around the issuer can determine whether the model is viable.
Sources
- Financial Stability Institute, stablecoin issuer entities and activities, 27 August 2026
- EU Markets in Crypto-Assets Regulation, Article 48
- FCA cryptoasset regime policy statements, 30 June 2026
This content is informational only and is not legal advice.