In 2025, regulatory progress across key markets moved decisively from ambiguity toward implementation. Rather than constraining activity, these frameworks have begun to formalize legal foundations required for the next phase of global crypto adoption, in our view.
In the United States, the rescission of SAB 121 and the passage of the GENIUS Act marked a meaningful shift. Banks are no longer penalized for holding digital assets on balance sheets, opening the door for regulated custody, settlement, and treasury services.
At the same time, stablecoins have been classified outside securities law, with clear reserve and disclosure requirements tied to cash and short dated U.S. Treasuries. This has enabled compliant stablecoins to integrate directly into core payment infrastructure, accelerating their use in settlement, payroll, and institutional cash management.
Europe has advanced in parallel through MiCA, which introduced a harmonized regulatory regime for crypto asset issuance and services across all member states. Beyond compliance, MiCA has materially reoriented activity toward regulated instruments and venues, as non-compliant issuers are progressively sidelined.
This has driven professionalization across reserve management, disclosure, and governance, while encouraging liquidity to consolidate around compliant stablecoins and platforms. For institutional participants, the result is greater legal certainty for cross border spot activity, collateral usage, and onchain settlement within the EU, reducing operational risk and enabling participation at scale.
The United Kingdom has taken a more incremental approach, but with similar directionality. The proposed stablecoin and custody rulebooks, alongside dedicated prudential regimes for crypto firms, are aligning crypto market infrastructure with banking standards for safeguarding, capital, and risk management. The result is a clearer path for UK regulated venues to support institutional flows.
Building on this trend, the United Arab Emirates has emerged as a key hub for digital assets and stablecoins. Dubai's VARA has tightened leverage and formalized token issuance standards, while Abu Dhabi's ADGM has streamlined approvals, introduced activity-based capital rules, and prohibited privacy and algorithmic stablecoins. Together, these regimes establish a predictable, institutional grade framework for cross border trading, custody, and stablecoin and RWA issuance.
Across jurisdictions, the common thread is operational usability rather than permissiveness. Stablecoins are becoming embedded within payment, settlement, and treasury workflows, while custody, surveillance, and capital standards align with institutional norms. These frameworks establish the legal and operational prerequisites for issuing, settling, and holding tokenized instruments within regulated market structures.
Looking into 2026, the main risk is not a reversal of this progress, but uneven implementation and compliance costs across regions. For institutional investors, the key questions will be where regulated liquidity concentrates, how capital rules treat tokenized collateral, and how quickly large banks and payment providers integrate stablecoins and tokenized assets into their operating models.
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