Stablecoins — crypto assets whose value is pegged to a fiat currency, most often the US dollar — surpassed a market size of over $300 billion as of 2026. This scale has prompted regulators to move beyond mere "guidance" to full-scale legal frameworks. In this article, we compare the US GENIUS Act, the EU's MiCA regulation and the legal position in Turkey.
Important: This article is for general information only and does not constitute legal advice. Stablecoin regulation is evolving rapidly at both the global and local level; please seek current expert advice for your specific situation.
A stablecoin is a crypto asset that relies on a reserve to keep its value stable. The most common type is the "payment stablecoin", backed one-to-one by dollar reserves (such as USDT and USDC). As these assets are now used across a wide range — from cross-border payments to corporate treasury management — they have come into regulators' focus on financial stability and anti-money-laundering grounds. The fact that the vast majority of global supply is pegged to the dollar also makes the matter strategically significant for the US.
The GENIUS Act, which entered into force in the US on 18 July 2025, established the first federal framework for payment stablecoins. Its core principles:
Implementing rules for the GENIUS Act continue to be written by the OCC, FDIC and FinCEN throughout 2026, with some obligations taking effect on a phased basis.
The EU's Markets in Crypto-Assets Regulation (MiCA) has applied its stablecoin provisions since December 2024. MiCA regulates stablecoins not as a single legal category but under two distinct types:
For significant issuers, MiCA requires 60% of reserves to be held as bank deposits at EU credit institutions. The grandfathering period for existing providers may extend to 1 July 2026 depending on member state choices.
There is no mutual recognition between the GENIUS Act and MiCA. This means issuers operating in both markets must maintain separate licences and separate reserve programmes. The reserve rules of the two regimes also differ: the GENIUS Act limits reserves to short-term Treasury bills and cash, while MiCA requires significant issuers to hold deposits at EU banks.
Practical consequence: Industry analyses point to the end of the "borderless stablecoin" era. A token of the same name (e.g. USDC) may be split into two legally distinct programmes — an EU version and a US version. The largest issuer, Tether, has indicated it does not intend to seek MiCA authorisation.
Turkey does not yet have a dedicated, standalone regulation for stablecoins. The legal framework is assessed within the broader crypto asset legislation:
For a Turkey-based fintech, OTC desk or institutional investor, using stablecoins requires multi-layered compliance:
At Koru Legal, we provide corporate advisory on stablecoin usage, cross-border payment structures and CASP/MASAK compliance. Contact us for regulatory-compliant structuring.
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