Three live regimes in 2026. HKMA Stablecoins Ordinance Cap. 656 (in force 1 August 2025), MAS single-currency stablecoin framework (finalised August 2023), JFSA Electronic Payment Instruments regime (Chapter III-3 PSA, in force June 2023, reserve rules relaxed June 2026).
HKMA issued the first two stablecoin-issuer licences on 10 April 2026, to HSBC and Anchorpoint Financial (Standard Chartered / HKT / Animoca Brands JV), out of 36 applicants received by 30 September 2025. The first batch covers HKD-referenced and multi-fiat-referenced programmes; no pure USD-referenced stablecoin has been HKMA-licensed yet.
The Stablecoins Ordinance (Cap. 656) commenced on 1 August 2025 and hands full supervisory jurisdiction over fiat-referenced stablecoin issuance to the Hong Kong Monetary Authority. The perimeter catches any person who issues a fiat-referenced stablecoin (FRS) in Hong Kong, any person who issues an FRS that references the Hong Kong dollar anywhere in the world, and any person who actively markets such issuance to the Hong Kong public, a deliberately broad extraterritorial scope modelled on the Banking Ordinance.
An applicant must be a company incorporated in Hong Kong or an authorised institution, hold paid-up share capital of at least HKD 25,000,000 and liquid capital of at least HKD 3,000,000, and evidence excess liquid capital covering at least twelve months of operating expenses. Senior management, chief executive, chief financial officer and chief compliance officer, must be ordinarily resident in Hong Kong. HKMA expects a local board sub-committee with oversight of reserve management, redemption operations and financial-crime controls, and the reserve manager (whether in-house or outsourced) must be an HKMA-regulated trust or authorised institution.
The statutory timeline proceeds through pre-application engagement, formal application, HKMA substantive review (performance pledge 9–15 months for stablecoin issuers), and on-site inspection before licence issuance. The first cohort opened on 1 August 2025; by the 30 September 2025 window close HKMA had received 36 applications, of which the first two licences were issued on 10 April 2026 to HSBC and Anchorpoint Financial. Pre-existing issuers who applied by 30 September 2025 could continue under a provisional arrangement until 31 January 2026, after which full Cap. 656 compliance is mandatory. Our Hong Kong crypto licence page maps the interaction between the Cap. 656 regime and the parallel SFC VATP licensing track.
MAS finalised the Single-Currency Stablecoin (SCS) framework in August 2023, integrating it into the Payment Services Act rather than creating a standalone statute. The perimeter covers non-bank issuers of stablecoins pegged to the Singapore dollar or any G10 currency. USD, EUR, GBP, JPY, CHF, CAD, AUD, NZD, SEK and NOK, with circulation above SGD 5 million. Bank-issued tokenised deposits remain outside the framework and are supervised through the Banking Act.
Four pillars anchor the MAS regime. First, value stability: reserves must be held 100% in cash, cash equivalents or short-dated sovereign debt of the pegged currency, with residual maturity not exceeding three months, and ring-fenced at a MAS-regulated custodian. Second, capital: base capital the higher of SGD 1 million or 50% of annual operating expenses, plus solvency liquid assets at least equal to 50% of annual opex or SGD 1 million. Third, redemption: par-value redemption within five business days of a valid request, with MAS pushing best practice towards T+1 or T+2. Fourth, disclosure: white-paper publication, monthly reserve-asset attestation by an independent auditor, and audited annual financial statements filed with MAS. Applicants typically slot in as Singapore Major Payment Institutions with DPT/SCS sub-services, and the MAS licence does not passport, distribution to non-Singapore residents is not automatic.
Japan restricts stablecoin issuance to three licensed categories: banks authorised under the Banking Act, Type-II / specified trust companies issuing trust-type stablecoins, and Type-1 funds-transfer service providers operating under the Payment Services Act. This issuer-only architecture was introduced by the 2022 PSA amendment and Chapter III-3 entered into force on 1 June 2023, defining fiat-referenced stablecoins as Electronic Payment Instruments (EPIs). JPYC's approval as the first fully compliant yen-referenced stablecoin validated the trust-type model.
Intermediation, custody or exchange of EPIs requires a separate EPI Service Provider (EPISP) licence with mandatory membership of the Japan Payment Service Providers Association (JPSA). The 6 June 2025 PSA amendment, in force by June 2026, introduces two structural changes. First, up to 50% of the reserve pool may be held in JGBs or US Treasuries with residual maturity of three months or less, or in early-termination time deposits, replacing the pure demand-deposit regime. Second, a new "ECISB" intermediary-lite licence lets non-custodial fintech apps distribute EPIs without full EPISP capital. See our Japan crypto licence page for the integrated CAESP / EPISP / ECISB map.
The APAC regimes converge on a narrow, high-quality liquid-asset reserve stack. Eligible reserve assets are: (i) demand or short-notice bank deposits with high-investment-grade credit institutions, (ii) sovereign bills or notes of the pegged-currency issuer with residual maturity of three months or less, (iii) repurchase agreements collateralised by the same sovereign securities with overnight or short-dated tenor, and (iv) for Japan post-June 2026, up to 50% in JGBs or US Treasuries under the same three-month maturity cap. Commercial paper, corporate bonds, money-market-fund units (except where expressly notified), and crypto collateral are excluded across all three regimes.
HKMA Cap. 656 overlays two additional constraints: reserves must be held in trust with an HKMA-regulated trustee, and the reserve pool must be segregated from the issuer's balance sheet such that insolvency of the issuer does not give general creditors recourse to holder claims. MAS requires reserves in the pegged currency, an HKD-pegged stablecoin cannot hold USD Treasuries as backing, and prescribes custody with a MAS-regulated deposit-taking bank or licensed custodian. The AML/KYC programme must include reserve-side controls: counterparty due-diligence, sanctions screening on custodians, and monitoring for concentration risk.
HKMA and MAS both require monthly attestation of reserves by an independent public accountant and full annual audit, with the Japanese EPI regime aligning on a monthly reconciliation and quarterly auditor-sign-off cycle. The monthly attestation must evidence, at minimum, the reserve balance as of the reporting date, the composition of the reserve pool by asset class and by custodian, the aggregate stablecoins in circulation on-chain, and reconciliation between circulation and reserves. Results are filed with the regulator and published in summary form on the issuer's public website, typically within 5–10 business days of month-end for HKMA and MAS.
The annual audit is a full ISA 805 or equivalent engagement covering the reserve ledger, custody confirmations, issuer financials, internal control over financial reporting, and a management letter. HKMA additionally requires an annual compliance audit covering Cap. 656 governance, redemption SLA performance, complaint handling and AML controls. Issuers should scope the attestation engagement against the PCAOB-aligned standard used by USDC's monthly reports and Tether's BDO quarterly attestation, rather than the lighter agreed-upon-procedures format. MAS in particular has signalled that AUP is below supervisory expectations.
HKMA mandates par-value redemption within one business day (T+1) of a valid redemption request, with no redemption fee beyond narrow, cost-based pass-through. MAS requires redemption within five business days but expects best practice at T+1 or T+2 and has not approved an SCS issuer on longer windows. The Japanese EPI regime permits the trust or bank issuer to apply the underlying funds-transfer service rules, generally same-day for in-jurisdiction redemption. Across all three, redemption-right waivers, circuit-breakers or blacklisting of redemption for commercial reasons are prohibited, only sanctions screening, valid AML holds and court-ordered freezes justify a delay.
Customer-protection rules add a trust overlay: segregation of reserves from the issuer's own assets, absolute priority of holder claims over general creditors in insolvency, and prescribed minimum disclosures on the redemption process, channels, cut-off times, fees, identity verification. Complaint escalation to the regulator is a statutory right in HK and Singapore, and the issuer must publish an accessible complaints policy and report aggregate complaint data in annual filings.
Algorithmic stablecoins, tokens whose peg relies on automated buy/sell of a volatile governance token or protocol-native collateral without fiat or HQLA backing, are excluded from licensing in Hong Kong, Singapore and Japan. Cap. 656 ties the regulated perimeter to fiat-referenced stablecoins with 1:1 HQLA backing; the MAS SCS framework explicitly names "single-currency pegged stablecoin" with 100% reserve backing, excluding both crypto-collateralised and algorithmic designs from the SCS label; and the Japan EPI regime caps "electronic payment instruments" at fiat-referenced, fully reserved tokens.
Crypto-collateralised stablecoins (for example, DAI) are not illegal but fall outside the regulated stablecoin perimeter and instead trade as crypto-assets on the VATP, DPT or CAESP trading venues, with the issuer continuing to face exchange-token listing criteria rather than stablecoin-issuer licensing. Overcollateralisation, algorithmic rebasing and governance-token burn mechanisms do not, in themselves, create a compliant path to HKMA, MAS or JFSA licensing.
None of the three regimes passports to the others. An HKMA-licensed HKD stablecoin offered to Singapore-resident users requires MAS compliance or distribution via a MAS-licensed intermediary under the PSA DPT service. MAS does not recognise HKMA licensing as equivalent for the purposes of offering to the Singapore public. The reverse also applies: a MAS-licensed SCS cannot be actively marketed to the Hong Kong public unless the issuer enters the Cap. 656 regime or distributes via an HKMA-licensed authorised institution.
For Japan, the EPI distribution rules require the EPISP licence or, from 2026, the ECISB intermediary licence, a MAS SCS cannot be sold to Japanese retail users without this Japanese-side wrapper. The territorial reach of Singapore's FSMA Part 9 DTSP regime is particularly important: a stablecoin issuer based in Singapore serving only non-SG clients still needs to either hold an MPI licence or wind down the Singapore operation, because MAS has stated it will grant DTSP licences for outbound-only models only in "extremely limited" circumstances.
South Korea does not yet license stablecoin issuance domestically. The Financial Services Commission is drafting the Digital Asset Basic Act across 2025–2026, with a dedicated won-referenced stablecoin regime expected alongside distribution rules covering foreign-issued stablecoins. USDT and USDC are presently tradable on ISMS-certified Korean VASPs but are subject to VASP-side Travel Rule and blocklist controls, not issuer-side licensing. Our South Korea crypto licence page tracks FSC consultation papers and the DABA legislative calendar; the working assumption is that foreign stablecoins will need issuer-equivalent reserve and attestation disclosures before Korean VASPs are permitted to continue listing them under the new regime.
| Item | HKMA (Cap. 656) | MAS (SCS) | JFSA (EPI) |
|---|---|---|---|
| Statute | Stablecoins Ordinance Cap. 656, in force 1 Aug 2025 | Payment Services Act + SCS framework Aug 2023 | PSA Chapter III-3, in force 1 Jun 2023; 6 Jun 2025 amendment live Jun 2026 |
| Eligible issuers | HK-incorporated company or authorised institution | Singapore-incorporated non-bank MPI or bank | Banks, Type-II / specified trust companies, Type-1 funds-transfer providers |
| Eligible pegs | Any fiat; HKD extraterritorial trigger | SGD or G10 currencies | JPY and other fiat via trust or bank |
| Minimum capital | HKD 25M paid-up + HKD 3M liquid + 12-month opex | SGD 1M base + 50% opex solvency liquid assets | Bank / trust / FTSP capital per underlying licence; reserve-side rules apply |
| Reserve rule | 100% HQLA, trust-segregated | 100% HQLA in pegged currency, ≤3-month maturity | Up to 50% JGBs / US Treasuries (≤3m) from Jun 2026 |
| Redemption SLA | T+1 at par | Within 5 business days; T+1/T+2 expected | Aligned with underlying funds-transfer rules |
| Attestation | Monthly + annual audit + annual compliance audit | Monthly + annual audit | Monthly reconciliation + quarterly sign-off |
| Algorithmic pegs | Out of perimeter | Excluded from SCS label | Out of EPI perimeter |
| Typical timeline | 12–24 months | 9–18 months | 15–24 months |
| First licences | HSBC + Anchorpoint, 10 Apr 2026 | Issued incrementally since 2023 | JPYC (trust-type, yen) approved; ongoing |
A realistic scoping call answers four questions: which peg currency, which holder-base jurisdiction, which distribution channel and which reserve custodian. The answers often push the same programme towards a different lead jurisdiction than the founders initially assume, a USD-pegged retail stablecoin pointed at Southeast-Asian users is almost always MAS-led, whereas an institutional HKD programme anchored in two bank-sponsor shareholders is Cap. 656-led. Our legal-opinions service issues the token-classification and licensing-scope opinion that banks and investors need before the first application spend.
The MAS SCS framework supports G10-currency-pegged issuance. HKMA has not yet licensed a pure USD-referenced stablecoin, the first batch focused on HKD and multi-fiat. Japan's EPI regime is currently structured around yen and trust-type stablecoins.
HKD 25M paid-up share capital plus HKD 3M liquid capital, plus excess liquid capital ≥ 12 months opex. The licence carries the Cap. 656 obligations on reserves, redemption and audit.
From the first cohort: applications received by 30 September 2025; first two licences issued 10 April 2026, roughly 6 months from cohort close, with substantial pre-application work in the months preceding the cohort opening.
Yes, the MAS framework licenses non-bank issuers under PSA with prescribed reserve, audit and redemption obligations.
The 6 June 2025 PSA amendment, in force by June 2026, permits up to 50% of stablecoin reserves to be held in JGBs or US Treasuries (≤3 months residual maturity) or early-termination time deposits. This makes Japan competitive vs HK and SG for yen-backed and trust-type stablecoin issuance.
Cap. 656 requires full 1:1 backing with high-quality liquid assets segregated in trust, par-value redemption within one business day (T+1) of a valid request, monthly public reserve reporting and annual independent audit. Capital is HKD 25M paid-up plus HKD 3M liquid capital and ≥12 months opex buffer. See our Hong Kong crypto licence page.
MAS's August 2023 SCS framework covers stablecoins pegged to the Singapore dollar or any G10 currency (USD, EUR, GBP, JPY, CHF, CAD, AUD, NZD, SEK, NOK). Reserves must be 100% backed at all times in cash, cash equivalents or ≤3-month sovereign debt of the pegged currency, held with a MAS-regulated custodian. See our Singapore crypto licence page.
Under the revised Payment Services Act (in force June 2023), fiat-referenced stablecoins qualify as Electronic Payment Instruments and can be issued only by licensed banks, money-transfer agents (Type-1 funds-transfer service providers) or trust companies, a narrow, issuer-only model. Distribution is a separate EPI Service Provider licence. See our Japan crypto licence page.
The Digital Asset Basic Act being drafted by the FSC in 2025–2026 contemplates a dedicated won-referenced stablecoin regime and distribution rules that would require exchanges to apply issuer-equivalent reserve and disclosure tests for foreign stablecoins. USDT and USDC are expected to remain tradable only if the issuer meets Korean-equivalent backing and attestation standards.
Across HKMA, MAS and JFSA the acceptable reserve stack is narrow: cash on deposit with high-quality banks, short-dated T-bills or sovereign bills (≤3 months residual maturity for MAS and the Japanese expansion), and repo against the same government securities. Commercial paper, corporate bonds and crypto collateral are excluded. The Japanese cap permits up to 50% in JGBs or US Treasuries under the 2025 PSA amendment.
HKMA and MAS both require monthly attestation by an independent public accountant plus annual full audit. The attestation must confirm the reserve balance, asset composition and reconciliation to stablecoins in circulation. Results are filed with the regulator and published in summary form on the issuer's website, typically within 5–10 business days of month-end.
HKMA and MAS both mandate par-value redemption within one business day (T+1) of a valid request, with no redemption fees beyond narrow cost pass-through. Algorithmic stablecoins without fiat or HQLA backing are excluded from licensing in HK, SG and JP, the ordinances and PSA amendments explicitly define the protected regime around fiat-referenced, fully backed instruments.
Cross-border offering, e.g. an HKMA-licensed stablecoin being offered to Singapore users, is permitted only if the issuer separately complies with MAS rules, or distributes via a MAS-licensed intermediary under the PSA DPT service. MAS does not passport HKMA licences and the reverse is also true.
HKMA opened a 3-month application window from 1 August 2025. Pre-existing issuers that applied by 30 September 2025 could continue operating under a provisional arrangement until 31 January 2026, after which full Cap. 656 compliance is mandatory.
Authorised institutions (banks) such as HSBC were eligible in the first cohort without a fresh incorporation. Non-banks must incorporate in Hong Kong, meet the HKD 25M paid-up capital floor and satisfy HKMA that their board, senior management and risk function are HK-resident.
Japan separates the regime into two legs: only banks, trust companies or Type-1 funds-transfer service providers may issue EPIs, while intermediation, custody or exchange of EPIs requires a separate EPI Service Provider (EPISP) licence regulated under Chapter III-3 of the PSA with JPSA self-regulatory membership. The upcoming 2026 ECISB intermediary-lite licence reduces the load for non-custodial fintechs.
A 30-minute scoping call with the country lead. HKMA, MAS or JFSA, written approach, capital plan and audit cadence.
