Research on Stablecoin Regulatory Policies in Major Countries and Regions

Contents

Preface

Stablecoin Regulatory Policies in the U.S

Stablecoin Regulatory Policies in Canada

Stablecoin Regulatory Policies in the EU

Stablecoin Regulatory Policies in Hong Kong

Stablecoin Regulatory Policies in Japan

Stablecoin Regulatory Policies in the Middle East

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Preface

Stablecoin are unique assets in the cryptocurrency market, defined by the Bank for International Settlements (BIS) as “cryptocurrencies whose value is linked to fiat currency or other assets.” Unlike traditional cryptocurrencies (such as Bitcoin), stablecoins aim to avoid drastic price volatility by anchoring their value to fiat currency or other assets. The emergence of stablecoins has provided a relatively stable value carrier in the cryptocurrency market, especially in the decentralized finance (DeFi) sector, where their widespread use adds liquidity and stability to scenarios such as on-chain transactions and lending.

Currently, stablecoins can be divided into two main categories: asset-backed (collateralized) stablecoins and non-asset-backed (non-collateralized) stablecoins. Based on the type of collateral, stablecoins are further classified into four types: fiat-backed stablecoins, commodity-backed stablecoins, crypto-backed stablecoins, and algorithmic stablecoins.

  1. Fiat-Backed Stablecoins: This type of stablecoin maintains its value by holding fiat currency (such as USD, EUR, etc.) in bank accounts or other financial instruments. Each unit of stablecoin has a corresponding amount of fiat currency as a reserve, which means holders can exchange it for fiat under specific conditions. Notable examples include USDT (Tether) and USDC (USD Coin).

  2. Crypto-Backed Stablecoins Unlike fiat-backed stablecoins, crypto-backed stablecoins use other cryptocurrencies as reserves to maintain their value. For instance, DAI is issued by collateralizing cryptocurrencies like Ethereum. Since the value of the collateralized crypto assets can fluctuate significantly, these stablecoins typically require over-collateralization to ensure they can maintain their pegged price during periods of high volatility in the crypto market.

  3. Commodity-Backed Stablecoins: Commodity-backed stablecoins derive their value from physical commodities (such as gold, oil, etc.), with their value tied to the market prices of these commodities. These stablecoins generally attract those looking to invest in commodities via digital currencies. An example is PAX Gold (PAXG), backed by gold.

  4. Algorithmic Stablecoins: Algorithmic stablecoins maintain a stable value by adjusting their supply through smart contracts and predefined rules. These stablecoins do not rely on reserve assets but instead use dynamic supply adjustments to stabilize their price. A prominent example of an algorithmic stablecoin is Ampleforth.

According to Coinglass, on October 20, 2024, the market capitalization of Tether’s USDT exceeded $120 billion, marking a historic high, while USDC’s market cap approached $35 billion. In a report released in October this year, a16z noted that stablecoins account for nearly one-third (around 32%) of daily cryptocurrency usage. Since their inception, stablecoins have rapidly become a focal point within the crypto asset industry, drawing attention from governments worldwide, leading to regulation. From the rise and fall of Luna and UST a few years ago to recent rumors about impending regulatory actions on USDT by U.S. authorities, every move involving stablecoins has significant implications for the crypto industry, affecting the interests of crypto practitioners. In this context, the content team at TaxDAO has reviewed stablecoin regulatory policies across regions, including the United States, European Union, Hong Kong, Japan, Canada, and the Middle East, compiling the findings into this research report.

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