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UK and US Take Action Together: New Currency Regulation Reshapes Licensing Rules

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红线说书
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15 hours ago
AI summarizes in 5 seconds.

On May 14, 2026, London and Washington each sent different yet equally sharp signals. Sasha Mills, Executive Director of the Bank of England, publicly stated that a type of token pegged to fiat currency should be classified as "a new form of money" and indicated that the Bank of England plans to open formal application channels for "systemic issuers" by the end of 2026, effectively announcing that such privately pegged assets will be brought into the core vision of monetary regulation. At the same time, the U.S. Senate Banking Committee advanced the CLARITY Act legislative process, attempting to provide legal clarity for the digital asset market through statutory law. Fidelity, managing assets worth trillions of dollars, immediately supported this through public policy channels, claiming the bill offers "a balanced regulatory approach" that not only brings clear rules to the digital asset market but also helps maintain the U.S.'s global leadership in this field. One route is an administrative path guided by rules from central banks and regulators, and the other is a legislative path that involves Congress enshrining classifications and boundaries into law. On the same day, the two contrasting routes of the UK and the US were viewed by the industry as the starting point of a competitive acceleration period regarding the regulatory narrative around digital assets in major jurisdictions. For issuers of pegged assets, global trading platforms, and traditional financial institutions accustomed to operating under clear licensing frameworks, this means that in the coming years, the qualifications for market access, the scope of business, and capital risk requirements they face will be systematically rewritten according to the newly delineated regulatory boundaries for "new forms of money" in their respective jurisdictions.

The Bank of England recognizes new forms of money for regulation

In London, Sasha Mills pulled pegged assets, originally regarded as "technological products," forcefully into the monetary discourse with the statement "stablecoins are a new form of money." This is not merely a matter of wording upgrade but a clear declaration: the central bank is prepared to regard this type of pegged asset as money and payment tools, incorporating it into the same regulatory coordinate system as traditional payment systems. Following the 2025 "Digital Securities Sandbox" and "Stablecoin Regulatory Roadmap," the Bank of England is no longer just discussing experimentation and pathway design but has provided a temporal anchor—planning to open application channels for "systemic issuers" by the end of 2026—and sending a key signal: pegged assets capable of impacting the payment system and being intended for the public will be regulated as financial infrastructure.

The term "systemic issuer" is close to a shadow version of "systemically important infrastructure" in the regulatory context: not every small-scale token project needs to apply, but once the scale, coverage, and use cases reach a level that could impact financial stability, the issuer must enter the specialized channel set by the central bank. The Bank of England simultaneously emphasized that regulators would not "choose sides" between tokenized deposits and pegged assets, deeming it too early to determine which type of new money is more suitable for specific use cases. This serves as an invitation to the market: whether large payment companies, crypto issuing institutions or banks tentatively entering pegged asset businesses, anyone planning to scale up, deepen, or even replace some existing payment functions must anticipate whether they will be recognized as a "systemic issuer" in the future and prepare for the capital requirements, operational constraints, and prudent regulations associated with entering this new licensing trajectory.

The regulatory games and thresholds before the application channels

Once recognized as a "systemic issuer," it implies being pulled into a prudent regulatory track similar to systemically important payment systems: higher capital buffers, more detailed risk management frameworks, and more frequent reporting obligations will transfer from the payment world to this new type of money. The framework prepared by the Bank of England in 2025 through the "Digital Securities Sandbox" and "Stablecoin Regulatory Roadmap" is precisely that—an entire regulatory skeleton aimed at private pegged assets. For large payment companies, technology firms, or crypto issuers aiming at systemic scale, it's no longer just about obtaining a registration certificate; they need to build their capital strength, compliance teams, and internal risk control systems based on the standards required for systemically important infrastructure in advance.

More subtly, the central bank has made it clear that it will not "choose sides" between tokenized deposits and this type of new money, thus reserving experimental space for both banks and non-bank entities: banks can bet on the tokenized deposit path, while tech and crypto companies can continue to promote pegged asset models, but those recognized as "systemic issuers" in the future will face heavier prudent constraints. The issue, however, is that so far, the regulators have only provided a timeline of "opening application channels by the end of 2026" without announcing specific admission standards and technical details. The absence of details has left potential applicants to draw analogies based on existing payment and electronic money regulatory experiences, yet they cannot accurately design capital structures, reserve management models, and risk segregation arrangements between business and other group parts. This has made the period before the application window opens feel more like a game of who dares to place resource bets and establish compliance "shells" in the face of regulatory uncertainty.

The legislative battle of CLARITY across the Atlantic

Unlike the Bank of England's exploratory approach with regulatory roadmaps and sandboxes, the rules dispute across the Atlantic has been elevated to the Senate hearing table. The CLARITY Act is seen as one of the key digital asset legislations recently advanced by the U.S. Senate Banking Committee, and its legislative positioning is straightforward: to bring various digital assets, which have long oscillated between different regulatory frameworks for securities, commodities, etc., back into a predictable classification and rule system, providing the market with dependable legal clarity. At the same time, Fidelity has publicly endorsed this through public policy channels, stating that the bill offers "a balanced regulatory approach," emphasizing both legal certainty and protection for U.S. investors, and reminding legislators that this will affect whether the U.S. can maintain its leadership position in the global digital asset field.

The real pressure behind this legislative battle lies in the years of regulatory ambiguity that have accustomed U.S.-based trading platforms, issuers, and custodians to operate under the shadow of "ex post facto enforcement": whether a product issuance is considered a security or a commodity determines which licensing framework and type of regulatory accountability they must face; yet the answers often only come retrospectively via investigation letters or lawsuits. Once CLARITY moves forward under the Senate Banking Committee's push, it means that the U.S. chooses to clarify boundaries through congressional legislation. Its immediate consequence is to force market participants to redesign their business lines, compliance architectures, and license combinations under the new classification rules, while traditional financial institutions will also use this to assess whether to expand their custody and trading service offerings. For the industry, this is not only a transition from regulatory ambiguity to rule transparency but also a race to see who can first complete structural adjustments and seize compliance advantages under the new legislative coordinates.

Traditional giants bet on legal clarity

On the same day that the Senate Banking Committee advanced the CLARITY Act, Fidelity's public endorsement truly brought the "rules game" to the forefront. As a traditional financial institution managing assets worth trillions of dollars, Fidelity chose not to sit on the sidelines but issued a statement through public policy channels, directly naming their support for CLARITY, stating it provides "a balanced regulatory approach" that will bring "legal clarity" to the digital asset market, benefit "U.S. investors," and help ensure America's leadership in the global digital asset field. For such institutions, this is not merely a question of stance; it is the fundamental premise of the asset management business model: only when regulatory classifications, liability boundaries, and licensing paths are written into the bill and regulatory manuals can compliance departments calculate costs, and product teams dare to design scalable business lines in the new asset category.

Fidelity's choice is also a signal management act to its peers. Long-term experience tells traditional institutions that only in conditions of relatively stable regulatory rules and clear legal responsibility boundaries will banks, brokerages, and asset management companies launch new asset category products on a large scale. Given Fidelity's definition of CLARITY as a "balanced" plan, it provides positive endorsement on this judgment. For asset management companies and large banks still observing from the sidelines, this endorsement serves as both a policy barometer and a lobbying reference template: whoever bets first and participates in shaping these rules stands a better chance of gaining regulatory recognition for a first-mover advantage in future digital asset custody, trading, and product issuance. As the two paths in the UK and US almost simultaneously enter an acceleration phase, traditional giants like Fidelity are no longer just passive adaptors but are actively using their public stance to seek a predictable and expandable compliance coordinate system.

License and route choices under the U.S.-UK regulatory competition

As London, led by the central bank, brings "new forms of money" into the system through administrative rules, Washington opts to send the CLARITY Act to Congress. These two routes themselves resemble two completely different investment promotion brochures. The Bank of England's commitment is: to open application channels for systemic pegged asset issuers before the end of 2026, first providing a countdown date and then slowly carving out risk requirements and technical standards in the details; this means potential issuers can obtain operational-level "tickets" earlier and complete pilots in London, connecting to the banking system and trading platforms. The core selling point of the American path, on the other hand, is that once the CLARITY Act successfully passes through both houses and is signed by the president, the digital asset market will obtain a higher hierarchical classification and market structure rules—Fidelity's public endorsement is precisely because of this clarity that will have nationwide enforceability once legislated. Therefore, for global pegged asset issuers and platforms, choosing to pursue licenses first in London or waiting for Washington to provide final rules becomes a trade-off between speed and certainty: the former is a faster but more variable administrative route, while the latter is a slower but higher-level legislative route.

This route difference will quickly project onto end users and decentralized finance in terms of liquidity and scenario access. As the systemic framework from the Bank of England is implemented and the CLARITY Act outlines compliance boundaries for the U.S. market, newly licensed pegged assets will find it easier to enter regulated custody, trading, and payment infrastructures, while assets still in regulatory vacuums will be pushed towards gray areas and may be confined to self-circulating in on-chain native scenarios. For protocol developers, accessing "licensed" pegged assets means they can connect with banks, traditional asset managers, and cross-border settlements; sticking with unregulated assets means facing increasingly tightened risk parameters from compliance counterparts. The real uncertainty lies in how strict the unpublished admission details from the Bank of England will be, how the CLARITY Act will be rewritten in legislative negotiations, whether the EU and Asian regulators exploring similar frameworks post-MiCA will follow suit, and ultimately, how these details will redistribute compliance costs and market access, as well as the collective migration direction of industry participants in this new game.

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