U.S. vs. EU Stablecoin Regulation: How the Revised STABLE Act Stacks Up Against MiCA and GENIUS

As the U.S. inches closer to stablecoin regulation, a newly amended version of the STABLE Act has reframed the discussion around what responsible issuance looks like—and who can participate. Meanwhile, the European Union’s MiCA framework is already in effect, and the GENIUS Act continues to gain traction in the U.S. Senate as a more flexible counterpoint.

For stablecoin issuers, investors, and product teams, understanding how these three regulatory frameworks compare is essential for shaping a go-to-market and long-term compliance strategy. The revised STABLE Act offers new clarity, but also creates sharper contrasts with MiCA and GENIUS.

In this article, we explore how the new STABLE Act proposal (H.R. 2392 / 4766) compares with its legislative peers—and what founders need to consider when choosing a jurisdiction.

🔗 To review our previous analysis, read: MiCA vs. GENIUS vs. STABLE: Choosing the Right Regulatory Regime for Your Stablecoin Launch

Legal Status and Implementation Timeline

• MiCA (EU): Enacted and enforceable across all 27 EU member states. EMT and ART issuer rules took effect in 2024.
• Revised STABLE Act (U.S. House): House committee-approved proposal with bipartisan input. Not yet law.
• GENIUS Act (U.S. Senate): Active bipartisan bill with broad support but no final vote.

Takeaway: MiCA provides immediate legal certainty. U.S. issuers must continue planning for multiple scenarios.

Stablecoin Issuer Licensing: MiCA vs. GENIUS vs. STABLE

The revised STABLE Act introduces a two-tier licensing system:

• Tier 1 Issuers: Federally insured depository institutions (banks, credit unions) can issue stablecoins within existing frameworks.
• Tier 2 Issuers: Nonbanks (including fintechs and crypto-native entities) may issue stablecoins but must register with the Federal Reserve and adhere to special requirements.

Founder Insight: If your project isn’t a federally regulated bank, the Tier 2 pathway offers legal recognition—but it comes with monthly reporting, reserve audits, and full Fed supervision. State licenses alone will no longer suffice.

Reserve and Redemption Requirements

All three frameworks emphasize reserve safety, liquidity, and par-value redemption, but with differences in oversight.

• MiCA mandates 1:1 backing of EMTs with high-quality liquid assets and daily redemption rights.
• GENIUS Act also requires full reserves, including cash or Treasuries, but permits both state and federal oversight.
• STABLE Act (2025) matches these requirements, while assigning the Federal Reserve as examiner and enforcement authority for nonbanks.

Operational Insight: Treasury and legal teams should anticipate Fed examinations and real-time disclosures under Tier 2. Operational readiness around liquidity management is critical.

Oversight and Enforcement Model

• MiCA enforces compliance through national authorities in each EU state.
• GENIUS Act blends federal guidance with state regulator autonomy.
• STABLE Act (2025) centralizes all stablecoin supervision under the Federal Reserve.

This divergence has major implications for how issuers structure their legal entities, compliance teams, and treasury operations.

Founder Insight: For startups used to working with state regulators (e.g., NYDFS or Wyoming), the shift to direct Federal Reserve oversight under the STABLE Act may require new compliance roles and outside counsel.

Monthly Reporting and Consumer Disclosures

All three frameworks require:

• Reserve disclosures
• Clear redemption policies
• Disclaimers regarding insurance status (e.g., FDIC non-coverage)

The revised STABLE Act further expands consumer protections by mandating:

• Disclosure of affiliate relationships
• Marketing clarity around risks and redemptions
• Timely notification to users about changes in reserve structure

Founder Insight: STABLE Act disclosure standards are on par with MiCA but exceed those proposed in GENIUS. Issuers must invest in plain-English reporting and compliance tooling.

Strategic Takeaways for Founders

• Europe-first teams will benefit from MiCA’s single passport model and market maturity.
• U.S.-based projects must plan for layered federal bills and choose between flexibility (GENIUS) and formal centralization (STABLE).
• Global issuers may need dual structures to accommodate both MiCA and evolving U.S. frameworks.

Founders should ask:

• Am I prepared for Fed-level supervision?
• Do I need state-level agility, or am I planning for institutional partners?
• Will MiCA’s ban on yield-bearing tokens require me to change my tokenomics?

Timeline of Regulatory Milestones

Final Thoughts on U.S. and EU Stablecoin Regulation in 2025

The revised STABLE Act raises the stakes in the U.S. regulatory debate—offering a defined path for nonbank stablecoin issuers, while imposing stricter federal oversight. Compared to MiCA and the GENIUS Act, it presents both a clearer federal regime and a higher operational burden.

For many issuers, the decision won’t be binary. MiCA is already law. U.S. bills are moving targets. But smart structuring today can open markets tomorrow.

At Veritas Global, we help stablecoin issuers, funds, and financial platforms navigate these evolving regulatory waters—from European licensing to U.S. entity structuring and compliance programs.

Planning your next stablecoin launch? Contact us today to future-proof your roadmap.

📘 Also read: Our original analysis of the STABLE Act’s 2025 revision.