Comparison: MiCA vs GENIUS Act vs Singapore (MAS) vs Hong Kong (HKMA)
| Topic | EU — MiCA | US — GENIUS Act | Singapore — MAS | Hong Kong — HKMA |
|---|---|---|---|---|
| Jurisdiction & status | EU-wide regulation. Stablecoin rules (Titles III/IV) applicable since 30 June 2024; full MiCA since 30 December 2024. | US federal law. GENIUS Act signed 18 July 2025; primary rules take effect on the earlier of 18-month implementation date or 120 days after final rulemaking. | Singapore. MAS Stablecoin Regulatory Framework finalised August 2023; applies to SCS-labelled single-currency stablecoins pegged to SGD or G10 currencies. | Hong Kong. Stablecoins Ordinance enacted May 2025, in force 1 August 2025, administered by the HKMA. |
| Scope | Two token classes: E-money Tokens (EMT, pegged to one fiat currency) and Asset-Referenced Tokens (ART, basket or non-fiat assets). | 'Payment stablecoins' redeemable at par for fiat. Excludes deposits, securities, and algorithmic stablecoins. | Single-Currency Stablecoins (SCS) pegged to SGD or any G10 currency, issued in Singapore with circulation > S$5 million. | Fiat-referenced stablecoins (FRS) issued in Hong Kong or pegged to HKD, regardless of issuer location. |
| Who can issue | EMTs: only credit institutions or authorised e-money institutions. ARTs: credit institutions or MiCA-authorised ART issuers. | Insured depository institutions, federally qualified nonbank issuers (OCC-supervised), or state-qualified issuers below the US$10 bn threshold. | MAS-licensed entities (typically Major Payment Institutions or banks) granted SCS issuer status. | Only HKMA-licensed FRS issuers; minimum paid-up capital HK$25 million. |
| Reserve composition | 1:1 reserve in highly liquid assets; 30% of EMT reserves in cash deposits across multiple credit institutions (60% for significant EMTs). | 1:1 reserve in US currency, insured demand deposits, short-dated Treasuries (≤93 days), or overnight repos backed by Treasuries. | Reserves held in cash, cash equivalents, or short-dated (≤3 months) sovereign debt of issuing-currency rating ≥ AA−. | Reserves of high-quality, highly liquid assets denominated in the pegged currency; market value ≥ par value of outstanding stablecoins at all times. |
| Redemption | Holders have a permanent right of redemption at par from the issuer, free of charge for EMTs. | Issuer must redeem at par within one business day; clear public redemption policy required. | Redemption at par within 5 business days of request. | Redemption at par within 1 business day of a valid request, without unreasonable fees. |
| Interest to holders | Prohibited — issuers and CASPs may not pay interest on EMTs or ARTs. | Prohibited — payment stablecoin issuers may not pay yield or interest to holders. | Not prohibited by the SCS framework, but yield is typically not offered by SCS issuers. | Prohibited under the Stablecoins Ordinance. |
| Foreign issuers | Non-EU stablecoins cannot be offered in the EU unless issued by an EU-authorised entity; significant USD-denominated EMTs face additional caps on EU trading volume. | Foreign issuers may offer payment stablecoins in the US only if their home regime is determined by Treasury to be comparable and reciprocal. | Only stablecoins issued by MAS-licensed entities may carry the 'MAS-regulated stablecoin' label; foreign stablecoins may circulate but without the label. | Any stablecoin pegged to HKD, or offered to the Hong Kong public, requires an HKMA licence regardless of issuer domicile. |
| Algorithmic stablecoins | Not banned outright, but cannot qualify as EMTs or ARTs without reserve backing. | Effectively prohibited — payment stablecoins must be fully reserve-backed. | Excluded from the SCS framework. | Excluded; FRS must be fully backed by reserves of equivalent value. |
| Supervisor | National competent authorities + EBA for significant tokens. | OCC (federal nonbanks), federal banking agencies, or state regulators. | Monetary Authority of Singapore (MAS). | Hong Kong Monetary Authority (HKMA). |
Key takeaways
All four regimes converge on full reserve backing, par redemption, and a ban (or de-facto ban) on algorithmic designs.
MiCA and HKMA explicitly ban interest to holders; GENIUS does the same in the US. Singapore does not yet formalise an interest ban.
MiCA uniquely caps non-EUR EMT trading volumes in the EU to protect monetary sovereignty.
Sources
Regulation (EU) 2023/1114 (MiCA), OJ L 150, 9.6.2023.
Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act), Pub. L. 119-27 (2025).
MAS Response to Public Consultation on Proposed Regulatory Approach for Stablecoin-Related Activities, 15 Aug 2023.
Stablecoins Ordinance (Cap. 656), Hong Kong, in force 1 Aug 2025.
For reference only — not legal advice.