Stablecoin issuance is becoming a licensed activity in every major market, and the licence is the easy part. The US OCC rule implementing the GENIUS Act takes effect on 18 January 2027, Hong Kong granted its first two issuer licences in April 2026, and MiCA has applied to e-money tokens since 30 June 2024. What decides whether a stablecoin survives is whether holders can get in and out at par, in size, on the worst day.
Who decides this
The board decides whether to become a stablecoin issuer at all; the CFO and general counsel own the two halves of the answer. The board is accountable for the business case, the risk appetite and the decision to put the institution’s name on a liability that must be redeemable at par. The CFO owns reserves, custody, liquidity and the attestation cycle. General counsel owns the licence, the entity structure and the distribution contracts.
Those two halves meet at redemption. Assign one of the two officers as the single owner of the redemption path, end to end, before anything else is built.
Where should the issuer be licensed, and through which entity?
License the issuer where the currency’s holders and banking partners are, and expect that to mean a dedicated entity rather than the parent bank in most markets. The four regimes below differ on who may issue, what backs the token and how fast holders must be paid. They agree on two points: full reserve backing and no interest to holders.
| United States (GENIUS Act) | European Union (MiCA, e-money tokens) | Singapore (MAS) | Hong Kong (Stablecoins Ordinance) | |
|---|---|---|---|---|
| Status, October 2026 | Signed 18 July 2025; OCC final rule effective 18 January 2027 | Applies to issuers since 30 June 2024 | 2023 framework finalised; draft Payment Services Act amendments to implement it consulted on to 16 October 2026 | In force since 1 August 2025; first two licences granted 10 April 2026 |
| Who may issue | Subsidiaries of insured depository institutions, federal qualified issuers approved by the OCC, or state qualified issuers | Credit institutions or e-money institutions only | Draft law: holders of a new stablecoin issuance licence; banks issue through a separate licensed non-bank entity | Licensed issuers of fiat-referenced stablecoins issued in Hong Kong, or referencing the Hong Kong dollar anywhere |
| Licence or notification | Approval by the primary federal regulator, the OCC or a state; state issuers above $10 billion move to federal supervision within 360 days or stop net new issuance | No separate authorisation for the token; white paper notified to the home regulator | Recognition as a “MAS-regulated stablecoin” only if every requirement is met | HKMA licence; paid-up capital of at least HK$25 million unless an authorised institution |
| Reserve requirements | At least 1:1, identifiable and segregated; eligible assets include US currency, deposits at insured banks, short-term Treasury bills, certain repos, government money market funds and tokenized forms of these | At least 30% of funds in separate accounts at credit institutions; remainder in highly liquid, low-risk assets in the same currency; extra liquidity rules once significant | Draft law: reserves at least equal to par at all times, in segregated trust accounts with permitted custodians | Full backing at all times; market value at least par; high-quality, liquid assets held on trust |
| Redemption | Published redemption policy; two-business-day maximum in the OCC rule | At any time and at par | At par within five business days (2023 framework) | At par, within one business day for onboarded users |
| Interest to holders | Prohibited | Prohibited | Prohibited under the draft law | Prohibited |
Sources: OCC Bulletin 2026-50, the Austrian regulator’s MiCA token page, MAS and the HKMA (all open in a new tab). Singapore’s draft law has no enactment date yet.
Our view: for a bank, the subsidiary or separate-entity route is the default everywhere except the EU, where a credit institution can issue directly. For a non-bank, the US federal route and the Hong Kong licence carry the clearest supervision; the EU route requires an e-money licence first.
What should the reserves hold?
Hold the shortest, most liquid assets the regime allows, and size the cash portion to your worst plausible redemption day rather than to the regulatory floor. Every regime above sets a floor; none sets your redemption profile.
The US rules show how the floor works. Under the OCC’s February 2026 proposal, a reserve shortfall stops new issuance immediately, and a shortfall lasting 15 consecutive business days forces liquidation and redemption. The final rule gives issuers more flexibility in managing reserves while keeping core liquidity, diversification and concentration requirements. In the EU, at least 30% of funds must sit in bank deposits, and an issuer whose token becomes significant takes on extra liquidity and stress-testing duties. Plan for those from day one if growth is the goal.
Stablecoin reserves earn income for the issuer, not the holder. Hong Kong states this outright: reserve income or losses belong to the licensee. That income is the business model, and it shrinks as the cash share rises. The CFO should present that trade-off to the board explicitly.
Who holds the reserves, and how are they separated?
Reserves should sit with a third-party custodian, legally separated from the issuer’s estate, with a monthly attestation that a holder can read. Segregation is required in all four regimes; bankruptcy remoteness depends on how the trust or account is drafted in each.
Monthly reporting is becoming standard in the US. The OCC proposal required monthly public reserve reports examined by a public accounting firm and certified by the chief executive and chief financial officer. Build the reporting pipeline before launch, because the first report is due before the operations team has settled.
Keep custody of reserves and custody of the token keys as separate decisions. They carry different risks and often sit with different providers.
How will the coin reach holders, and how will they leave?
Distribution and redemption are one system: every channel that brings holders in must also be able to take them out at par, through banking hours, weekends and stress. Design both directions before signing any distribution partner.
Three constraints now shape distribution. First, the yield ban limits the incentives a stablecoin issuer can pay. The OCC final rule dropped the proposal’s presumption that certain affiliate and third-party arrangements evade the ban; it will review each arrangement on its facts instead. Second, in the EU, an ESMA opinion of October 2026 (opens in new tab) tells national authorities that crypto-asset service providers should not provide services for non-compliant e-money tokens, beyond a strictly limited wind-down of existing holdings. Third, in Hong Kong, retail investors may only be offered stablecoins from licensed issuers.
Secondary-market depth matters as much as primary redemption. Most holders will exit on an exchange, not through the issuer. If the coin trades below par there, the redemption right is irrelevant to them.
The Bank for International Settlements (opens in new tab) argues that stablecoins fall short on singleness, meaning acceptance at par everywhere. Treat that as a design specification, not a criticism. Par on every venue is the product.
What goes wrong: a launch plan that assumed liquidity
The usual failure is a stablecoin that is licensed, fully reserved and audited, and still trades away from par in its first month. The plan assumed liquidity would arrive with the licence. It does not.
The pattern is familiar. Mint and redeem run only through the issuer, during banking hours, for onboarded institutions. Exchanges list the coin, but no market maker has committed inventory or a spread. A large holder sells on a venue, the price slips, and arbitrageurs who could restore par cannot redeem fast enough to close the gap.
Rules can make this worse in a stress event. The OCC’s February 2026 proposal would have stretched the redemption period to seven calendar days once requests topped 10% of outstanding issuance in 24 hours. Commenters objected, and early reports say the final rule swaps that automatic extension for notice to the OCC and a request for more time. Any extension protects the issuer, but holders feel it as a gate. The remedy is to contract liquidity before launch: authorised minters, market-maker commitments, banking partners with weekend coverage, and a tested playbook for a redemption run.
How Alcyone approaches it
Alcyone treats the launch week as the unit of planning: which exchanges, market makers and banking partners are signed, what each has committed, and who is on the line when the first large redemption arrives. Its partners introduce issuers to exchanges, market makers and data platforms, review those contracts, and stay on through launch and the post-launch report; see Alcyone’s exchange, launch and partnerships advisory (opens in new tab). The first deliverable is a fixed-scope assessment in week two, and there is no obligation to use TrustSwap products.
For the reserve side, segregated reserve custody through Panthea (opens in new tab) places reserves in segregated accounts at Blockfort, a Swiss-regulated financial intermediary and VQF member, with account reporting that supports reserve attestation. The issuer should confirm with its regulator whether that arrangement meets the custody rules of its own regime.