The regulatory frameworks for stablecoins in the EU (MiCA) and the US (the GENIUS Act of 2025) were drafted independently and reached many of the same conclusions. Combined with the Swiss FINMA guidance of 2024 and the MAS Stablecoin Framework of 2023, we now have four major frameworks that overlap meaningfully on reserve composition, redemption guarantees, and issuer authorisation. This brief examines the practical consequences for tokenised-asset issuers using stablecoins as the cash leg in delivery-versus-payment settlement, and argues that the overlap has made a single global cash-leg inventory feasible for the first time.
- 01Four major stablecoin frameworks (MiCA, GENIUS Act, FINMA guidance, MAS Framework) now agree on the core requirements: fully-reserved issuance, redemption guarantees, authorised issuer registration, and segregation of reserve assets.
- 02USDC, EURC, RLUSD, and the Swiss-franc-denominated stablecoins under FINMA guidance are simultaneously compliant with multiple frameworks, making them usable as universal cash legs in cross-jurisdictional DvP settlement.
- 03The practical consequence is that a tokenised-asset issuer in Zurich can settle with a subscriber in Singapore using a stablecoin authorised in both jurisdictions, without either party needing to engage their local correspondent bank. The settlement finality is atomic and the audit trail is continuous.
- 04The binding constraint is no longer regulatory; it is operational readiness of transfer agents, custodians, and fund administrators to process stablecoin cash legs as a standard cash instrument rather than an exotic one.
1. Regulatory convergence, not harmonisation
The four frameworks were drafted independently and are not harmonised in any formal sense. They do, however, converge on the same core requirements. A stablecoin is fully reserved in safe assets; reserves are segregated from the issuer's operating balance sheet; holders have a legal right to redemption at par; the issuer is authorised and supervised by a named competent authority.
This convergence is not an accident. It reflects the fact that stablecoins are fungible cash-equivalents and the policy question they raise — what protects holders if the issuer fails — has a limited number of sensible answers. Each framework arrived at a similar answer by a different route.
2. The emergence of dual-compliant coins
USDC was authorised under the GENIUS Act as a Permitted Payment Stablecoin in Q4 2025 and is treated as a compliant asset-referenced token under MiCA by virtue of Circle's Irish authorisation. EURC holds equivalent dual status. RLUSD has authorisations in both the US and the UAE and is working through the MiCA process. A growing set of CHF-denominated and SGD-denominated stablecoins are multi-compliant in their respective home regions.
The practical effect is that a short list of stablecoins is usable as a cash leg in settlement between parties sitting in different jurisdictional regimes, without either party needing to engage a correspondent bank to translate between currencies or legal regimes.
3. The correspondent banking displacement
Correspondent banking processes roughly $156 trillion of cross-border value per year. The value added is partly liquidity, partly compliance, partly legal-regime translation, and partly pure plumbing. Of those four functions, legal-regime translation is the one that regulated stablecoins most directly displace.
We do not expect correspondent banking to vanish. We do expect its share of cross-border settlement to compress meaningfully over the next five years, with the most compressible category being routine, low-complexity, mid-sized transfers between counterparties in regimes whose stablecoin frameworks have converged.
4. The operational gap
The binding constraint is no longer regulatory. It is operational. Transfer agents, custodians, and fund administrators routinely process wire instructions in milliseconds; stablecoin cash legs add complexity that these institutions are still working through — wallet allowlisting, reserve-asset reporting, redemption-failure procedures, and accounting for on-chain fees.
This is solvable and is being solved. But it is the reason that the displacement we describe will arrive gradually rather than abruptly.
This paper will be available as a signed PDF. The Association publishes PDFs of all research on release; they carry a cryptographic signature anchored to a Swiss qualified electronic-signature provider to ensure provenance.
Boli Association. (2026). Regulated stablecoins as cash legs in DvP settlement. Boli Association Policy Brief No. BA-2026-01. Zurich.