Stablecoin regulation is no longer being discussed in isolation on either side of the Atlantic.
Officials from the United States and the United Kingdom have expanded talks covering stablecoins, tokenized markets and digital asset oversight as Washington begins putting the GENIUS Act into practice.
The discussions point toward closer regulatory coordination. Not one shared rulebook—at least not yet—but a serious attempt to prevent the US and UK markets from drifting too far apart.
That matters for issuers hoping to operate across both jurisdictions. Two completely different systems would mean duplicated reserves, separate corporate structures and a pile of additional compliance costs.
US Regulators Bring the GENIUS Act to London
The latest discussions took place during the 13th meeting of the UK-US Financial Regulatory Working Group, hosted in London on July 8, 2026.
Senior officials from HM Treasury and the US Treasury attended alongside representatives from the Bank of England, Financial Conduct Authority, Federal Reserve, Securities and Exchange Commission, Commodity Futures Trading Commission, Federal Deposit Insurance Corporation and Office of the Comptroller of the Currency.
Digital finance took up a noticeable part of the agenda.
US officials briefed their UK counterparts on the implementation of the GENIUS Act and the continuing effort to establish a broader digital asset market structure. The two sides also discussed tokenization, payment modernization and the G20 roadmap for improving cross-border payments.
No new law came out of the meeting. No grand transatlantic crypto agreement either.
Still, the direction was difficult to miss. Both countries want digital assets to grow inside regulated markets rather than around them.
Stablecoins Must Be Fully Backed
The clearest point of agreement concerns reserves.
In a separate joint statement on stablecoins published on July 14, the US and UK said stablecoins presented as money should be backed at least one-to-one with high-quality, liquid assets.
In plain terms, an issuer should not create more stablecoins than it can reliably redeem.
The two governments also support segregating reserve assets from an issuer’s operating funds. Stablecoin holders should have a clear legal claim to those reserves, especially if an issuer collapses or enters bankruptcy.
Those principles sound obvious. The actual rules underneath them can become messy very quickly.
Which assets count as sufficiently liquid? Where can reserves be held? Who gets priority during insolvency? What happens when an issuer is licensed in one country but serves customers in another?
Those are the details now sitting on the table.
Cross-Border Access Could Be the Bigger Story
The US and UK are exploring a pathway that could allow a stablecoin approved in one jurisdiction to enter the other market.
It is still only a policy goal. There is no automatic passport for stablecoin issuers.
Even so, formal recognition between the two markets could become one of the most important outcomes of the talks. An issuer operating under US rules might eventually gain access to UK payment or capital markets without rebuilding its entire operation from scratch.
The arrangement would likely depend on both systems producing comparable outcomes around reserves, redemption, custody and consumer protection.
Comparable does not mean identical. That distinction gives regulators room to keep domestic rules while reducing unnecessary duplication.
For companies such as Circle, PayPal and other firms developing regulated digital money products, that kind of access could make expansion considerably less painful.
Bank of England Eases Its Stablecoin Approach
The timing is notable because the Bank of England has already softened parts of its proposed systemic stablecoin framework.
Earlier proposals included holding limits of £20,000 for individuals and £10 million for businesses. The central bank dropped those limits after industry criticism and replaced them with a temporary £40 billion issuance guardrail for each systemic stablecoin.
This changes the pressure point. Instead of limiting how much each user can hold, the Bank would initially control the total size of an individual systemic stablecoin.
The reserve structure was adjusted as well.
Under the revised steady-state framework, systemic issuers would be allowed to hold 70% of their backing assets in short-term UK government debt. The remaining 30% would sit as non-interest-bearing deposits at the Bank of England.
The earlier proposal required 40% to be kept at the central bank.
It is a small-looking percentage change with fairly large commercial consequences. More interest-bearing government debt means a more workable business model for issuers. Too much money trapped in non-interest-bearing accounts could make a UK stablecoin unattractive before it even reaches scale.
The US Has Moved First
The GENIUS Act has changed the pace of the conversation.
The United States now has a federal framework for payment stablecoins moving toward implementation. The UK, meanwhile, is still assembling the final pieces of its own system.
The FCA is expected to oversee qualifying UK stablecoin issuance, custody and trading. Stablecoins judged to be systemically important would fall under joint regulation from the FCA and the Bank of England.
That split structure gives the UK a way to regulate smaller products differently from stablecoins that become widely used for payments.
It also creates more moving parts.
US issuers entering Britain may need to deal with different regulators depending on their size, currency denomination and role in the financial system. UK issuers looking west will face their own questions about federal supervision and market access.
Closer coordination will not remove all of that. It may stop it from becoming unmanageable.
A Shared Direction, Not a Shared Rulebook
There is still plenty left unresolved.
Foreign-issued stablecoins need a clear legal status. Regulators must decide how reserve assets can be held across borders. Failure procedures need to work when customers, issuers and custodians are spread across multiple countries.
Then there is the larger political question: how much regulatory recognition is either side genuinely willing to grant?
For now, the US and UK have agreed on the broad shape of responsible stablecoin growth—full backing, reliable redemption, protected reserves and room for cross-border use.
The next test is turning those principles into rules that companies can actually use.
The Financial Regulatory Working Group is expected to meet again in early 2027. Until then, stablecoin issuers remain subject to separate US and UK requirements, even as those requirements slowly begin moving in the same direction.
