Key takeaways
- Three live regimes in 2026: HKMA Stablecoins Ordinance (in force 1 Aug 2025), MAS single-currency stablecoin framework (finalised Aug 2023), JFSA EPI regime (in force Jun 2023).
- HKMA issued the first two licences on 10 April 2026. HSBC and Anchorpoint Financial JV, out of 36 applicants.
- HKMA threshold: HKD 25M paid-up + 100% reserve backing + T+1 redemption at par.
- Japan's 2025 reserve relaxation permits up to 50% of reserves in JGBs/Treasuries from June 2026.
- No purely USD-pegged stablecoin licensed in HK yet; MAS framework supports G10 currencies.
Three live APAC stablecoin regimes in 2026
Three Asia-Pacific jurisdictions run operational fiat-referenced stablecoin regimes in 2026: Hong Kong under the HKMA Stablecoins Ordinance (Cap. 656), Singapore under the MAS single-currency stablecoin framework, and Japan under the Electronic Payment Instruments regime in Chapter III-3 of the Payment Services Act. Two further APAC jurisdictions are adjacent. South Korea, where the Digital Asset Basic Act has been drafted but stalled, and Australia, where stablecoin issuance is captured through general AUSTRAC and ASIC obligations rather than a dedicated regime.
APAC's direction of travel differs from the EU and the United States. EU MiCA (in force 30 June 2024) treats fiat-referenced stablecoins as e-money tokens (EMTs) or asset-referenced tokens (ARTs) and requires credit-institution or e-money-institution status. The US GENIUS Act (signed July 2025) authorises federally or state-chartered "payment stablecoins" with 1:1 Treasuries or cash reserves. The APAC regimes sit in between, stricter than US on reserve quality and redemption, more flexible than MiCA on multi-fiat scope, and, since Japan's 2025 amendment, meaningfully more flexible on reserve composition.
Hong Kong. Stablecoins Ordinance (Cap. 656)
In force 1 August 2025. The Stablecoins Ordinance catches any person issuing a fiat-referenced stablecoin (FRS) in Hong Kong, any person issuing an HKD-referenced FRS anywhere in the world, and any person actively marketing such issuance to the Hong Kong public. The Hong Kong Monetary Authority is the regulator; there is no dedicated Supervisory Policy Manual module, the Ordinance plus the HKMA's 29 July 2025 implementation guidelines are the operative rules.
Financial resources
- Paid-up share capital: HKD 25,000,000 (or 1% of total par value of stablecoins in circulation, whichever is higher).
- Liquid capital: HKD 3,000,000.
- Excess liquid capital equal to at least 12 months of operating expenses.
- Hong Kong-incorporated company limited by shares, or a Hong Kong-incorporated authorised institution under the Banking Ordinance.
Core obligations
- 100% reserve backing at all times in high-quality liquid assets (cash, short-dated sovereign debt, overnight reverse repos).
- Full segregation of reserve assets from the issuer's own balance sheet, held with an independent custodian.
- Absolute redemption right at par with T+1 settlement unless HKMA consents to a longer window.
- Locally based senior management. CEO, CFO, Chief Risk Officer and Money Laundering Reporting Officer ordinarily resident in Hong Kong.
- Monthly independent attestation of reserves plus annual audited accounts.
- White paper, disclosure of stabilisation mechanism, prohibition on interest-paying stablecoins.
First HKMA licences and pipeline
HKMA issued the first two stablecoin-issuer licences on 10 April 2026, to The Hongkong and Shanghai Banking Corporation Limited (HSBC) and to Anchorpoint Financial Limited, a joint venture of Standard Chartered Bank (Hong Kong), HKT and Animoca Brands. Both approvals were drawn from the 36 applications received by the 30 September 2025 deadline (Coindesk). The first batch covers HKD-referenced and multi-fiat-referenced programmes; no purely USD-pegged or offshore-USD stablecoin has been HKMA-licensed to date.
The provisional-licence window for pre-existing HKD-referenced issuers closed on 31 January 2026. From that date, any issuance into the Hong Kong market without a full HKMA licence is an offence under section 5 of the Ordinance, punishable by fine and imprisonment up to seven years.
Singapore. MAS single-currency stablecoin (SCS) framework
Finalised by the Monetary Authority of Singapore in August 2023 after two rounds of public consultation. The SCS framework covers stablecoins pegged to the Singapore dollar or to any G10 currency (USD, EUR, JPY, GBP, CHF, CAD, AUD, NZD, SEK, NOK). Multi-currency baskets and crypto-referenced stablecoins fall outside the framework and continue to be treated as digital payment tokens under the Payment Services Act.
Scope and licence structure
- Issuance of an SCS in Singapore is a regulated payment service under the Payment Services Act, integrated with the Major Payment Institution (MPI) authorisation, see the Singapore country page for MPI fundamentals.
- Only SGD or G10 pegs qualify. Algorithmic and crypto-collateralised stablecoins are explicitly excluded.
- Issuers must be Singapore-incorporated or a Singapore branch of a foreign bank authorised by MAS.
Reserve, capital and redemption rules
- 100% reserve backing in cash, cash equivalents or short-dated sovereign debt denominated in the peg currency.
- Segregated reserves held with a regulated custodian; monthly independent attestation published within 7 business days.
- Base capital of at least SGD 1 million or 50% of annual operating expenses, whichever is higher.
- Redemption at par within five business days of a valid request.
- White paper with prescribed disclosures; only SCS meeting all requirements may use the MAS-regulated stablecoin label.
As at April 2026, the two stablecoins publicly disclosed as operating under the SCS framework are StraitsX USD (XUSD) and StraitsX SGD (XSGD), both issued by StraitsX Issuance Pte Ltd under its MPI authorisation.
Japan. EPI regime (PSA Chapter III-3) and the 2025 reserve relaxation
Japan's stablecoin regime has two sides. Issuance is restricted to three categories under Chapter III-3 of the Payment Services Act (in force 1 June 2023): licensed banks, Type-II or specified trust companies (the trust-type stablecoin), and registered funds-transfer service providers. Intermediation and custody are handled by Electronic Payment Instruments Service Providers (EPISPs), who register separately and affiliate with the Japan Payment Service Providers Association as SRO.
The 2025 PSA amendment, 50% reserve flexibility
The PSA Amendment Act 2025 (enacted 6 June 2025, in force by June 2026) permits funds-transfer-type and trust-type issuers to hold up to 50% of stablecoin reserves in low-risk assets. Japanese Government Bonds or US Treasuries with residual maturity of three months or less, or early-termination time deposits, instead of 100% demand-deposit backing. This is the single most important APAC stablecoin policy change of 2025 for commercial economics: yen-backed and trust-type issuers can now generate a material reserve yield, closing part of the gap with US GENIUS-Act economics while retaining Japan's stricter conduct rules.
The same amendment introduces a new, lighter licence, the Electronic Payment Instrument and Crypto-Asset Intermediary Service Business (ECISB), for firms that intermediate between users and a principal EPISP or Crypto-Asset Exchange Service Provider without custodying user property. ECISB operators face no capital requirement but must register with the FSA and affiliate with a sponsoring principal that remains liable for their conduct.
See the Japan country page for the CAESP / EPISP / ECISB taxonomy in context.
South Korea. VAUPA today, DABA pending
South Korea has no live stablecoin issuer regime. Market-conduct rules for Korean-won stablecoins currently sit under the Virtual Asset User Protection Act (VAUPA), which entered into force on 19 July 2024 and is enforced by the Financial Services Commission and the Financial Supervisory Service. VAUPA does not license issuers; it regulates VASPs that list stablecoins and mandates cold-storage ratios, user-asset segregation, insurance or reserves, daily reconciliation and market-abuse surveillance.
The dedicated issuer regime, the Digital Asset Basic Act (DABA), was expected to advance through the National Assembly in late 2025 but stalled in December 2025 over a dispute between the Bank of Korea and the FSC about eligibility (Coindesk). BoK's position is that won-referenced stablecoins should only be issued by licensed banks or entities with at least 51% bank ownership, on financial-stability grounds. The FSC has argued for broader non-bank eligibility to retain innovation competitiveness vs Hong Kong and Singapore. A revised DABA draft is expected to advance in 2026. Until then, no won-referenced stablecoin can be issued domestically; Korean exchanges list foreign-issued USD stablecoins subject to VAUPA listing review. See the South Korea country page.
Australia, no dedicated licence, AUSTRAC plus ASIC coverage
Australia does not have a bespoke stablecoin licence. A domestic or foreign stablecoin issuer serving Australian users is captured through two general regimes. First, from 31 March 2026 the AUSTRAC Tranche-2 expansion brings virtual-asset services, including crypto-to-crypto exchange, custody, token issuance and transfers, within the AML/CTF Act. Newly captured services have until 1 July 2026 for full compliance obligations and 29 July 2026 to enrol with AUSTRAC.
Second, ASIC's new Digital Asset Platform (DAP) and Tokenised Custody Platform (TCP) regime, commencing 9 April 2027, with a transitional no-action lodgment deadline of 30 June 2026, will require an Australian Financial Services Licence for anyone advising, dealing or arranging dealings in DAP/TCP financial services. Indicative NTA for a custodial DAP operator is AUD 5 million, though the final tiering sits with ASIC's pending regulatory guide. The Reserve Bank of Australia's 2025 consultation signalled that private stablecoins should ultimately be treated as stored-value facilities under the Payments System (Regulation) Act, pending dedicated legislation. See the Australia country page for the combined AUSTRAC + ASIC pathway.
APAC stablecoin regimes, side-by-side
| Dimension | Hong Kong (HKMA) | Singapore (MAS) | Japan (JFSA) | South Korea | Australia |
|---|---|---|---|---|---|
| Statute | Stablecoins Ordinance Cap. 656 | PS Act + MAS Notices (Aug 2023) | PSA Chapter III-3 | VAUPA (today) · DABA (pending) | AML/CTF Act + Corporations Act |
| In force | 1 Aug 2025 | Aug 2023 (framework) | 1 Jun 2023 · amendment Jun 2026 | VAUPA 19 Jul 2024 · DABA stalled | Tranche-2 31 Mar 2026 · DAP 9 Apr 2027 |
| Scope | FRS issued in HK or HKD-ref globally | SGD + G10-pegged SCS only | Fiat-referenced EPIs; banks / trust / funds-transfer | Issuance regime pending | Captured via VASP + AFSL; no SC-specific |
| Min paid-up capital | HKD 25,000,000 | SGD 1M or 50% opex (SCS base) | Set per issuer track | TBD under DABA | AUD 5M NTA indicative (DAP custodial) |
| Reserve composition | 100% HQLA | 100% cash / short sovereign | Up to 50% JGBs/UST ≤3m (from 2026) | Pending | Pending |
| Redemption SLA | T+1 at par | 5 business days at par | Demand (funds-transfer) | Pending | Pending |
| Algorithmic allowed | No | No | No (EPI definition) | n/a (pending) | No dedicated rule |
| First licences | 2 issued 10 Apr 2026 (HSBC, Anchorpoint) | StraitsX operational under MPI | Multiple bank + trust programmes | None | None (regime not yet live) |
APAC vs MiCA vs the US GENIUS Act, quick framing
- EU MiCA (30 Jun 2024): EMTs and ARTs only; credit-institution or e-money-institution status; own-funds floor of EUR 350,000 or 2% of average reserve; whitepaper and home-regulator authorisation passportable EU-wide.
- US GENIUS Act (Jul 2025): permitted issuer = insured depository institution subsidiary, OCC-chartered national payment-stablecoin issuer, or state-regulated issuer under ≤USD 10 bn threshold; 1:1 reserves in USD cash, Treasury bills ≤93 days, or repos thereof; monthly attestation; no interest payable to holders.
- APAC: HK and SG are structurally close to MiCA on reserve quality (100% HQLA) but stricter on local incorporation and senior-management substance. Japan's 50% JGB/UST flexibility puts it closer to GENIUS economics while retaining APAC conduct rules.
Choosing the right issuing jurisdiction
The right APAC jurisdiction depends on peg currency, distribution, and treasury economics.
- HKD-pegged or multi-fiat programme: HKMA is the default. The 10 April 2026 first approvals signal HKMA's appetite for multi-fiat programmes from authorised institutions and strong JV structures. Expect 9–15 months to approval; budget a Hong Kong-incorporated vehicle and local senior management.
- SGD or G10-currency-pegged programme (including EUR, GBP, JPY): MAS under the SCS framework. Issuance sits inside an MPI authorisation, existing MPIs have the shortest path. Expect 12–18 months.
- JPY-pegged or trust-type programme: Japan EPI regime, particularly attractive after the 2025 reserve relaxation. Trust-bank partnership or Type-II trust-company structure recommended. Banking-sector relationship is a prerequisite.
- USD-pegged programme targeting APAC users: MAS under SCS is the cleanest APAC path today. HKMA is open in principle but has not yet licensed a USD-referenced programme. Many USD issuers continue to operate from non-APAC hubs and sell into APAC via licensed intermediaries.
- KRW-pegged programme: wait for DABA. Until the BoK-vs-FSC eligibility dispute is resolved, no domestic issuance pathway exists.
- AUD-pegged programme: prepare now under the AUSTRAC Tranche-2 + ASIC DAP transitional pathway; lodge AFSL applications before 30 June 2026 to secure ASIC no-action treatment through the 9 April 2027 commencement.
Further reading: stablecoin issuer service page · Hong Kong · Singapore · Japan · South Korea · Australia. To discuss jurisdiction selection for a live programme, book a 30-minute call with Jason Ka Wai Chan (HKMA) or Hiroshi Tanaka (JFSA EPI).
Frequently asked questions
What is the HKMA Stablecoins Ordinance?
Cap. 656 of the Laws of Hong Kong, in force 1 August 2025. It requires an HKMA licence to issue any fiat-referenced stablecoin in Hong Kong, to issue an HKD-referenced stablecoin anywhere in the world, or to actively market such issuance to the Hong Kong public.
Who received the first HKMA stablecoin licences?
On 10 April 2026 HKMA issued the first two licences, to HSBC and to Anchorpoint Financial Limited, a joint venture of Standard Chartered Bank (Hong Kong), HKT and Animoca Brands, out of 36 applications received by the 30 September 2025 deadline.
What is the capital requirement for an HKMA stablecoin issuer?
HKD 25,000,000 paid-up share capital (or 1% of par value in circulation, whichever is higher), HKD 3,000,000 liquid capital, and excess liquid capital equal to at least 12 months of operating expenses.
Which currencies are eligible under the MAS SCS framework?
Stablecoins pegged to the Singapore dollar or to any G10 currency. USD, EUR, JPY, GBP, CHF, CAD, AUD, NZD, SEK, NOK. Multi-currency baskets and crypto-collateralised stablecoins fall outside the framework.
Can non-banks issue fiat-referenced stablecoins in Japan?
Under Chapter III-3 of the Payment Services Act only three issuer categories are permitted, licensed banks, Type-II or specified trust companies (trust-type stablecoins), and registered funds-transfer service providers. Intermediation and custody are handled by separately registered EPI Service Providers.
What changed with Japan's 2025 PSA amendment for stablecoin reserves?
The 6 June 2025 amendment, in force by June 2026, permits up to 50% of reserves to be held in Japanese Government Bonds or US Treasuries with residual maturity of three months or less, or in early-termination time deposits, instead of 100% demand-deposit backing.
Can USD-pegged stablecoins be licensed in Hong Kong?
The Ordinance does not prohibit USD-referenced issuance, but as of April 2026 no purely USD-pegged programme has been HKMA-licensed. The first approvals cover HKD-referenced and multi-fiat-referenced programmes from authorised institutions.
How fast must a stablecoin issuer redeem at par?
HKMA requires T+1 settlement at par unless HKMA consents to a longer window. MAS requires redemption within five business days. Japan requires demand redemption for funds-transfer issuance.
What is DABA and why is South Korea delayed?
The Digital Asset Basic Act is Korea's planned stablecoin-issuer regime. Progress stalled in December 2025 over a dispute between the Bank of Korea (bank-only issuance with ≥51% bank ownership) and the Financial Services Commission (broader non-bank eligibility). A revised draft is expected to advance in 2026.
Does Australia have a stablecoin licence yet?
No. Issuers and intermediaries are captured via AUSTRAC virtual-asset-service obligations from 31 March 2026 and via ASIC's Digital Asset Platform / AFSL regime commencing 9 April 2027. The Reserve Bank of Australia's 2025 consultation signalled treating private stablecoins as stored-value facilities, pending dedicated rules.
How often are stablecoin reserves audited?
HKMA and MAS both require monthly independent attestation of reserves plus annual audited accounts. Japan requires segregated trust-bank or funds-transfer deposit verification on a continuous basis.
How does APAC compare with EU MiCA and the US GENIUS Act?
MiCA applies EU-wide from 30 June 2024 and requires credit-institution or e-money-institution status. The US GENIUS Act (July 2025) authorises federal and state payment stablecoins with 1:1 Treasuries reserves. APAC regimes are more fragmented but more permissive on multi-fiat scope and, in Japan's case, on reserve composition.