Payment stablecoins

The US experience

In May 2025, the US Senate approved the¹ GENIUS Act bill, which for the first time regulates stablecoins at the federal level. It introduces the concept of a “payment stablecoin” - a digital dollar-token redeemable at a “hard price” and fully backed by liquid reserves. The GENIUS Act is seen as a turning point in the development of regulation: standardized reserves and federal licensing make it possible to overcome the fragmentation of regulation at the level of individual states and make dollar stablecoins available to major financial² players.

GENIUS Act set forth the following:

− Issuance of stablecoins is allowed only³ to US residents holding one of three licenses.

− Collateral reserves must cover 100% of the number of tokens issued and may only include highly liquid assets such as US dollars on hand, balances with the Federal Reserve System (Fed), deposits with insured banks, Treasury bills with maturities up to 93 days, and overnight repo transactions where the same bills serve as collateral.

− Monthly disclosure of issue volume and token collateral structure, priority of holders' claims in case of issuer bankruptcy.⁴

In parallel, the STABLE Act is being discussed in the United States, which is similar to the GENIUS Act in many respects: it also requires 100% reservation and licensing but introduces more stringent requirements. Only federally licensed stablecoins are allowed, uniform rules apply to all issuers without a “preferential” threshold of $10 bn, a two-year moratorium on “algorithmic” and “endogenously⁵ secured” stablecoin is established, and foreign dollar tokens are allowed only with equivalent regulation in the country of their issuance.

The EU experience

The MiCA Regulation on the regulation of stablecoins has been adopted in the EU since 2023. There are 2 types of stablecoins:

1) Electronic money tokens (EMT) - cryptoassets pegged to only one fiat currency (e.g. Euro).

2) Asset-Related Tokens (ART) - cryptoassets pegged to one or more assets (a basket of fiat currencies, securities, commodities, etc.).

MiCA obligates issuers of such tokens to:

− Obtain an emission authorization from the national regulator.

− Release white paper.

− Hold 100% liquid reserves in reliable depositories and maintain equity capital of at least €350,000 or 2% of reserves.

Interest payments to stablecoin holders and any encumbrance of reserves are⁶ prohibited. For large issuers of stablecoins, the⁷ EBA is supervised and capital and liquidity requirements are increased. The EBA has the right to temporarily restrict issuance if the volume of transactions exceeds 1 million transactions or €200 mn per day. Thus, MiCA already implements the same key principles - full provisioning, mandatory licensing, instant redemption and enhanced oversight of large tokens - that are laid down in the US GENIUS Act. However, unlike MiCA, where “significant” issuers are defined by a set of qualitative criteria, in the US the transition to the federal regime comes when the issuance exceeds $10 bn.

Russia’s experience

Stablecoins are regulated in Russia in accordance with the Federal Law “On DFAs and Digital Currencies”. DFAs are recognized as “digital rights” fully secured by other property if the record of the rights is maintained in the blockchain system of an operator included by the Bank of Russia in the register. Stablecoin is treated as a DFA when the issuer guarantees a rigid price link to the underlying asset, maintains a 1:1 reserve in the operator's system and grants the holder a right of redemption. The Bank of⁸ Russia emphasizes that discussions on the nature and classification of stablecoins and whether a separate legal regime should be introduced for them or whether the existing regulation of DFAs and digital currencies should be applied continue.

It should be noted that holders of popular USDT and USDC stablecoins currently have no legally recognized right to exchange their stablecoins for the dollar equivalent. Issuers can only request redemption of these assets if certain conditions are met, and with reservations regarding the form of compensation and the limited range of persons entitled to such redemption.

From the monitoring issue No. 5 (17), May 2025. Download the full issue (PDF) · issue page at the Gaidar Institute