No. 136: A New Era of Stablecoins: Market Evolution and the Regulatory Race Shaping Digital Finance Across the European Union, the United Kingdom, and the United States

Abstract

The global financial system is undergoing a gradual but fundamental transition from physical currency toward digital forms of money, with stablecoins emerging as a key force within the blockchain-enabled landscape. Stablecoins are digital assets designed to maintain a stable value, most commonly pegged to a sovereign currency such as the U.S. dollar. Combining features of both traditional finance and distributed ledger technology, stablecoins enable near-instant settlement, greater transparency, and programmable functionality. Their structures vary, including fiat-backed, crypto-backed, algorithmic, commodity-backed, and hybrid models.
Initially used primarily within cryptocurrency markets as a low-volatility store of value and a stable medium for moving in and out of digital assets, stablecoins have evolved into a critical component of digital finance in recent years. Today, stablecoins facilitate payments, cross-border transfers, remittances, and peer-to-peer transactions, often more efficiently and at a faster speed than many legacy payment methods. In emerging markets with high inflation or volatile exchange rates, they offer a practical way to hold and transact in a U.S. dollar-equivalent value, potentially amplifying the reach of the U.S. dollar. In corporate finance, they are being progressively integrated into treasury operations, liquidity management, and programmable payment flows, offering continuous settlement and streamlined access to yield-bearing instruments.
Although some of these applications are still in their early stages, they point to a rapidly expanding role for stablecoins in the global financial system. As the technology matures, stablecoins are evolving from a single-purpose payment rail into a universal interoperability layer: programmable, interoperable, inclusive by design, and capable of seamlessly connecting today’s fragmented payment networks. In this role, stablecoins could fundamentally reshape the architecture of global finance, embedding programmable, on-chain money into its core, and enabling more efficient, transparent, and adaptive financial infrastructures, while redefining the very concept of money for a more integrated, accessible, and open financial world.
By early August 2025, the stablecoin market had reportedly reached a capitalization exceeding $250 billion, with annualized transaction volumes surpassing $33 trillion. This growth appears increasingly decoupled from broader cryptocurrency trading cycles, suggesting a self-sustaining growth cycle in stablecoin usage operating independently of broader trading activity. This rapid expansion has also made leading stablecoin issuers significant holders of U.S. Treasury securities, positioning them as influential participants in the Treasury market. Additionally, investments in stablecoin infrastructure have accelerated, driving high-profile IPOs, acquisitions, and sustained venture capital inflows.
The benefits of stablecoins are compelling, including near-instant settlement, increased efficiency, lower transaction costs, enhanced financial inclusion, and improved transparency. However, their expansion also presents multifaceted risks: potential runs and contagion risk triggered by financial instability or loss of confidence, insufficient liquidity in reserve assets, credit and counterparty risk, operational vulnerabilities, and legal uncertainties in insolvency scenarios, among others. On a macroeconomic level, stablecoins may challenge monetary sovereignty, contribute to the disintermediation of bank deposits, and create systemic exposure through interconnected reserve holdings.
In response, major jurisdictions are actively developing and implementing new regulatory frameworks to address these challenges. Recent legislative developments in major jurisdictions mark a pivotal shift toward comprehensive and coordinated stablecoin regulation, offering clearer legal parameters to effectively mitigate the identified risks and encouraging both institutional and retail adoption.
The European Union has pioneered regulatory action through the Markets in Crypto-Assets Regulation (MiCAR), which entered into force in June 2023 and became fully applicable in December 2024. Widely regarded as one of the most comprehensive crypto-asset frameworks globally, MiCAR requires asset-referenced token and e-money token issuers to be authorized and supervised, maintain fully backed reserves in segregated low-risk, high-quality liquid assets, and offer par-value redemption at all times. Interest payments on stablecoin holdings are prohibited, and issuers face strict disclosure obligations. However, while pioneering, the regime has also drawn criticism for its perceived protectionist stance. European regulators, particularly the European Central Bank, have voiced concerns about the systemic implications of widespread use of foreign stablecoins (especially U.S. dollar-backed tokens) in the Eurozone. As U.S.-regulated stablecoins expand globally, tensions may intensify with the European Union’s efforts to promote Euro-denominated alternatives.
In parallel, the United Kingdom has been advancing its own framework under the Financial Services and Markets Act 2023. Draft legislation released in April 2025 would bring issuance, custody, dealing, and other stablecoin-related activities within the regulatory perimeter. The framework gives the Financial Conduct Authority (“FCA”) primary oversight for issuance and custody, and the Bank of England responsibility for systemically important stablecoin systems. Consultations by the FCA and the Bank of England took place between 2023 and 2025, with full implementation expected in late 2025 or early 2026, pending parliamentary approval.
In the United States, the GENIUS Act, signed into law in July 2025, establishes a federal framework for payment stablecoins after years of policy uncertainty. The new framework will take effect on the earlier of 18 months after enactment or 120 days after the primary regulators issue final rules. The GENIUS Act permits issuance by insured depository institution subsidiaries, federally qualified entities, and state-chartered issuers operating under substantially comparable regimes, potentially enabling traditional financial institutions to reassert their role in digital money while allowing new entrants to enter the market. Foreign issuers can access the U.S. market through a safe harbor to be designated by the U.S. Treasury or by meeting specified conditions. The GENIUS Act mandates strict prudential oversight, including 1:1 reserve backing, transparency on reserve composition, and secure redemption. Consumer protection is strengthened through disclosure requirements, restrictions on reserve assets to safe, high-quality instruments, and priority claims for stablecoin holders on reserve assets in insolvency proceedings.
The next few years will be critical in determining how stablecoins will evolve and be progressively integrated within the broader financial system. While comprehensive regulation is essential for enabling stability and consumer protection, international cooperation among regulators becomes imperative to ensure that the current surge in regulatory momentum fosters unified global growth in the stablecoin market and supports the full realization of stablecoins’ transformative potential, without inadvertently contributing to market fragmentation or creating barriers to cross-border interoperability and competition due to divergent national frameworks.
Alongside regulatory developments, the growing influence of institutional participants and large tech companies is expected to accelerate the growth of the stablecoin ecosystem, driving demand for enhanced transparency, robust governance, and scalable infrastructure. This development is catalyzing new use cases, pushing the boundaries of stablecoin utility and structural innovation.
In this environment, achieving the “singleness of money” (where stablecoins are as trusted, fungible, and interoperable as traditional currencies) will depend on several critical factors: financial stability and operational resilience, ensuring that issuers can maintain stability and liquidity even under severe market stress; transparent governance, providing clear, accurate, and credible information on reserve composition, redemption rights, and risk management practices; and interoperability, both among different stablecoins and between stablecoins and the traditional financial system. Attaining this necessitates technical standards, common settlement layers, and shared protocols that allow for frictionless conversion, real-time redemption, and cross-chain functionality. Furthermore, global scale and ubiquity will require delivering everyday utility, seamless integration with existing financial infrastructures, intuitive user-centric design, and frictionless user experience. Mainstream adoption will also hinge on sustained public-private collaboration, as well as continued innovation in custody, identity, and compliance tools. If these conditions are met, stablecoins could emerge as a transformative infrastructure catalyst for a more connected, efficient, and inclusive global financial system.
Beyond market dynamics, stablecoins carry broader macroeconomic implications. Stablecoins, particularly those pegged to dominant reserve currencies like the U.S. dollar or euro, may exert significant influence on global monetary systems, potentially impacting monetary sovereignty and international currency competition. As stablecoins become more embedded in cross-border trade and finance, their evolution will more closely intersect with geopolitical and monetary policy considerations, regulatory coordination challenges, and central banks’ digital currency strategies.
Looking ahead, jurisdictions that deliver proportionate, coherent, and internationally coordinated regulation, balancing innovation with robust safeguards, will be able to attract high-quality issuers, leading institutional investors, and top-tier technology talent. Such environments will be best positioned to serve as hubs for stablecoin innovation, driving both domestic adoption and cross-border integration, enhancing consumer protection, and strengthening long-term sustainable growth and competitiveness.

Details

Author(s):
Publish Date:
August 22, 2025
Publication Title:
TTLF Working Papers
Publisher:
Stanford Law School
Format:
Working Paper
Citation(s):
  • Diana Milanesi, A New Era of Stablecoins: Market Evolution and the Regulatory Race Shaping Digital Finance Across the European Union, the United Kingdom, and the United States, TTLF Working Papers No. 136, Stanford-Vienna Transatlantic Technology Law Forum (2025).
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