US, UK Set Shared Stablecoin Rules but Stop Short of a Common Rulebook

The commitment sits inside a joint statement on stablecoins published on 14 Jul by the US Treasury and HM Treasury, released alongside a broader roadmap on tokenized assets and capital markets drawn up by the Transatlantic Taskforce for Markets of the Future. The taskforce was established by US Treasury Secretary Scott Bessent and UK Chancellor of the Exchequer Rachel Reeves in September 2025.

Follows London's tokenization plan

The statement came a day after London set out its ambition to tokenize wholesale markets, backed by a cross-industry taskforce of 54 banks, asset managers and digital-asset firms. Taken together, the plans amount to a bid by Washington and London to ensure the next generation of market infrastructure is built on standards they set, rather than ceding that ground to other jurisdictions.

Convergence, but not one rulebook

The two governments stopped well short of a common rulebook. They committed instead to convergence without harmonization, each pledging to "tailor its requirements to seek comparable outcomes for comparable risks and activities" to reduce fragmentation and avoid outcomes that would discourage cross-border competition.

In the statement, the governments said well-regulated stablecoins "have the potential to promote efficiency and competition in our financial systems, modernize financial market infrastructure, and improve cross-border payments and transactions."

The dollar question nobody raised

The statement made no explicit mention of the dominant role played by dollar-pegged stablecoins. According to DefiLlama, total stablecoin market capitalization stood at around $310bn as of 14 Jul, with Tether's USDT and Circle's USDC holding a combined 83%. That dominance has fed a wider debate over dollar hegemony and foreign monetary sovereignty, and it goes unaddressed in a document jointly signed by the country that issues the dollar and the country that does not.

Two regimes with different shapes

The UK and US have taken differing approaches to regulating stablecoins. The Guiding and Establishing National Innovation for US Stablecoins Act (GENIUS Act), signed into law on 18 Jul 2025, targets payment stablecoins and embeds dollar-backed tokens into a dual federal-state banking framework.

In the UK, the Bank of England (BoE) and the Financial Conduct Authority (FCA) have finalized a dual oversight model. The FCA regulates non-systemic issuers and retail conduct, while the BoE oversees coins that are systemic in scale, where failure could threaten financial stability.

The BoE also softened its original stance. A November 2025 consultation proposed individual retail holding limits of £20k per coin and corporate limits of £10mn per coin to prevent bank runs and destabilizing capital shifts.

What stablecoin holders would be owed

The shared principles include full backing by "high-quality liquid assets", segregation and custody of reserves, and a "clear and protected legal claim on reserves" for holders, including priority ahead of other creditors in insolvencies.

One-year tokenization workstream

The US and UK said they would begin a one-year engagement with a private-sector-led group focused on "industry experimentation and testing of cross-border use cases for tokenized assets" and on sharing best practices.

Among the agencies involved in the joint tokenized-asset and stablecoin working groups are the BoE, the Commodity Futures Trading Commission (CFTC), the FCA and the US Securities and Exchange Commission (SEC). They are tasked with identifying "common approaches to the regulatory treatment of tokenized assets, covering areas such as settlement finality of tokenized securities transactions and the potential eligibility and use of stablecoins and tokenized money market funds as margin collateral at central counterparties". Both governments "will consider increased use of flexible regulatory mechanisms, as appropriate".