Patrick Hansen
Patrick Hansen|May 26, 2026 12:33
The EU is the most restrictive jurisdiction for global/foreign stablecoins today. A great new analysis from Judith Arnal Martínez comparing stablecoin regulation across 7 major jurisdictions confirms this pretty clearly. Today, only the EU effectively requires local issuance through the so-called “multi-issuance” model. Other jurisdictions have taken a more pragmatic approach: foreign stablecoins can be recognised (U.S.), registered (UAE), distributed via locally licensed entities (Japan), or continue circulating outside the domestic framework for locally issued stablecoins, sometimes with targeted limitations (e.g. Switzerland, UK, Singapore). With the EU Commission now launching the MiCA review consultation, Judith Arnal is right to argue for a more proportionate framework based on mutual recognition of global stablecoins rather than an exclusionary approach calling for even greater restrictions. The real policy question isn’t “fully open vs fully closed.” It’s about preserving the benefits of an inherently global instrument and market while applying proportionate, risk-based local requirements. What often gets overlooked in the current debate around stablecoins and multi-issuance is that the EU already goes further than any other major jurisdiction in the world: requiring local issuance, full MiCA compliance, or for example issuance limits for non-EU currency stablecoins used at scale for real-world payments. Highly recommend the piece - link in comments.(Patrick Hansen)
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