BoliResearch
Regulations

Regimes by jurisdiction

Each entry is a named framework, what it actually governs, and the date that matters. Filter by jurisdiction, region or topic.

17
Region
Topic
Jurisdiction

European Union

Markets in Crypto-Assets Regulation (MiCA)

ESMA, EBA and national competent authorities
Phasing inStablecoinsService providers
Fully applicable 30 December 2024; final transitional deadline 1 July 2026

A single rulebook across the bloc covering the issuance of asset-referenced and e-money tokens and the authorisation of crypto-asset service providers. Authorisation is granted per service and passports across member states.

MiCA does not cover instruments that are already financial instruments — a tokenized share remains under existing securities law, not MiCA.

DLT Pilot Regime

ESMA and national competent authorities
In forceMarket infrastructureSecurities & tokenization
Applicable since 23 March 2023

Permits market infrastructures to trade and settle DLT-based financial instruments under temporary exemptions from rules written for conventional systems, within defined size limits.

It is a testing regime with caps, not a permanent licence category.

Transfer of Funds Regulation (recast)

National competent authorities
In forceAML
Applicable 30 December 2024

Applies the travel rule to crypto-asset transfers, requiring originator and beneficiary information to accompany a transfer between service providers.

Switzerland

DLT Act

FINMA
In forceSecurities & tokenizationMarket infrastructure
In force since 2021

Amends Swiss law to recognise ledger-based securities, so that an entry on a distributed ledger can be the legal record of the right rather than a copy of one, and creates a licence category for DLT trading facilities.

One of the few places where the ledger genuinely can be the register, which is why so many issuance vehicles are formed here.

United Kingdom

Stablecoin and cryptoasset regime

FCA and Bank of England
Phasing inStablecoinsService providers
Consultations through 2025; rules being finalised

A split framework in which the FCA supervises non-systemic stablecoin issuance and cryptoasset activities while the Bank of England takes systemic payment stablecoins.

Which regulator you face depends on scale, so the same product can change supervisor as it grows.

United States

GENIUS Act

OCC, Federal Reserve and state regulators
In forceStablecoins
Public Law 119-27

Federal legislation for payment stablecoins, setting who may issue and what reserves must back them. Issuers above $10 billion in outstanding tokens require a federal licence from the Office of the Comptroller of the Currency.

It is about payment stablecoins specifically. It does not make every token a permitted instrument.

Securities Act and Exchange Act

SEC
In forceSecurities & tokenizationMarket infrastructure
1933 and 1934, as applied to digital assets

Registration or an exemption is required to offer securities; dealing and arranging require broker-dealer registration; maintaining the register of a registered security is the transfer agent function.

Whether an arrangement is a security turns on the Howey test — the economics and conduct, not the label on the token.

Money transmission licensing

FinCEN and state regulators
In forceService providersAML
Ongoing

Federal registration as a money services business plus separate money transmitter licences in each state where the business operates.

Licensing is state by state, which is why US coverage is assembled over years rather than granted at once.

Singapore

Payment Services Act and stablecoin framework

MAS
In forceStablecoinsService providers
Stablecoin framework operational since August 2023

Licensing for payment services including digital payment token services, with a dedicated framework for single-currency stablecoins covering reserve backing, capital and redemption.

The most mature framework in Asia-Pacific, and used in commercial deployments rather than pilots.

Hong Kong

Stablecoins Ordinance (Cap. 656)

HKMA
In forceStablecoins
Effective 1 August 2025

A licensing regime for issuers of fiat-referenced stablecoins, covering reserve management, redemption and the persons who may issue.

Virtual asset trading platform regime

SFC
In forceService providersMarket infrastructure
Since June 2023

Licensing for virtual asset trading platforms, with requirements on custody, token admission and investor access.

Japan

Payment Services Act and FIEA

FSA
In forceStablecoinsSecurities & tokenization
Stablecoin provisions since June 2023

Treats fiat-backed stablecoins as electronic payment instruments issuable by banks, trust companies and funds transfer operators, while tokenized securities sit under the financial instruments law.

Japan drew the issuer perimeter tightly and early, which is why its stablecoin market looks different from others.

United Arab Emirates — Dubai

Virtual Assets Regulations

VARA
In forceService providersStablecoins
Since 2023

Activity-based licensing for virtual asset services in Dubai outside the DIFC, with rulebooks per activity including custody, exchange and broker-dealer services.

United Arab Emirates — federal

Payment Token Services Regulation

Central Bank of the UAE
In forceStablecoins
Effective August 2024

Defines payment tokens as crypto-assets fully backed by one or more fiat currencies and used for settlement or transfer, and licenses their issuance and related services.

United Arab Emirates — ADGM

Virtual asset and DLT foundations framework

FSRA
In forceService providersSecurities & tokenization
Ongoing

A common-law jurisdiction with an established virtual asset framework and a DLT foundations regime used for issuance vehicles and protocol entities.

Global standard

Recommendation 15 and the travel rule

FATF
In forceAML
Recommendation extended to virtual assets in 2019

Requires countries to license or register virtual asset service providers and to apply the travel rule, so that originator and beneficiary information accompanies transfers.

FATF is not a legislature. Its standards bind through national implementation, which is uneven in timing and detail.

Principles for financial market infrastructures, as applied to DLT

BIS, CPMI and IOSCO
In forceMarket infrastructure
Ongoing guidance

The expectations settlement systems are measured against — legal basis, settlement finality, operational resilience — applied to arrangements that use distributed ledgers.

Settlement finality here is a legal property, which a ledger's confirmation depth does not by itself establish.