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Cryptoasset and stablecoin regulation

Context

Following the sharp downturn in 2022, the crypto-asset market experienced a strong recovery, with total market capitalisation in the range of $2–2.5 trillion in 2025–2026, driven in particular by major crypto-assets such as Bitcoin and Ethereum. Stablecoins account for around 10% of this market. Since the end of 2025, the market has entered a new period of correction, illustrating its continued volatility. Despite strong growth over the past five years, the crypto-asset market remains relatively small compared to global financial assets (less than 1%).

The crypto-asset market continues to be largely driven by trading activity in unbacked crypto-assets, with a strong presence of retail investors, although it is becoming increasingly institutionalised, notably through the development of custody, trading and investment services provided by regulated financial institutions. Stablecoins are gaining importance as a bridge between crypto and traditional finance, while new use cases are emerging, particularly around tokenisation and payments.

In the EU, the Markets in Crypto-Assets Regulation (MiCA) has now been fully implemented, establishing a comprehensive framework for the issuance of crypto-assets and the provision of related services. While most provisions are in force, transitional arrangements in certain Member States have delayed full market alignment, with these regimes expected to phase out by mid-2026. MiCA introduces licensing requirements for service providers, rules for the issuance and governance of stablecoins, and market integrity and consumer protection provisions. Initial implementation shows progress in authorisations and supervisory convergence, although challenges remain regarding cross-border supervision, the treatment of decentralised activities and interactions with other EU frameworks.

At the international level, while the EU has been at the forefront of crypto-asset regulation, other jurisdictions are advancing their own frameworks. Japan and the UK have established or are developing comprehensive regimes covering crypto-asset activities and stablecoins. In the US, regulatory developments have accelerated, notably with the adoption of the GENIUS Act in 2025 establishing a federal regime for backed stablecoins used for payments and transactions, alongside ongoing market structure initiatives and regulatory actions to clarify the classification and oversight of crypto-asset activities. Internationally, the FSB, IOSCO and the BIS have also issued recommendations and standards addressing financial stability, market integrity and prudential risks associated with cryptoassets.

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