U.S.-UK joint statement on stablecoins, comparable outcomes instead of identical rules

During U.S. President Trump's state visit to the UK in September 2025, the finance ministers of the two countries set up the Transatlantic Taskforce for Markets of the Future. The U.S. Department of the Treasury and HM Treasury co-chair it, and financial regulators take part. On July 14, 2026, the Taskforce jointly published 10 recommendations, which HM Treasury called "initial" recommendations. On the same day, a joint statement on stablecoins was also issued under one of the recommendations.

The principle of similar outcomes for similar risks

The central sentence of the joint statement is that the two governments will each calibrate their requirements so that similar risks and activities lead to similar outcomes. Rather than creating a single common rule, the approach is to make each country's regime comparable with the other's. The statement also limits convergence of the two countries' rules to cases where it is appropriate and serves their shared interests. The recommendations state that the statement does not replace, or prejudge the outcome of, regulatory processes under way in each country.

As goals for the recommendations as a whole, the U.S. Department of the Treasury cited increasing cross-border financial activity, reducing unnecessary friction, and open, market-based standards. HM Treasury listed reducing market fragmentation and accelerating the adoption of tokenization, among others.

Five digital asset recommendations among the ten

The 10 recommendations are divided into five on digital assets and five on capital markets. The capital markets recommendations cover cross-border capital raising, the foreign private issuer regime, consolidated market data, and cooperation on accounting and auditing standards, among other topics. The five on digital assets are as follows.

1. An intention to engage, on a one-year basis, with a private sector-led group testing cross-border use cases for tokenized assets
2. Regulators exploring a common approach to the regulation of tokenized assets
3. Publication of a joint statement on stablecoins
4. Support for a policy framework in which stablecoins, tokenized deposits, and other forms of digital money are used together
5. Support for the review of the crypto-asset standard of the Basel Committee on Banking Supervision (the body that sets international prudential standards for banks)

The second recommendation names the Bank of England (the UK's central bank), the UK Financial Conduct Authority (FCA), the U.S. Securities and Exchange Commission (SEC), and the U.S. Commodity Futures Trading Commission (CFTC), among others. Settlement finality (the point at which a transaction is completed and can no longer be reversed) in tokenized securities trading is given as an example. The possibility of accepting stablecoins and tokenized money market funds (MMFs, funds that invest in short-term financial instruments) as margin collateral at central counterparties (CCPs, institutions that stand between the two sides of a trade and guarantee settlement) is also mentioned. The wording of the recommendation goes only as far as seeking a common approach. In November 2025, the Basel Committee decided to expedite its review of certain provisions of this standard, and in May 2026 it noted progress and said it would publish the outcome later in 2026.

Standards on reserve assets, redemption, and insolvency in the joint statement

The statement says the two governments support the safe growth of stablecoins in areas such as cross-border transactions and payments and settlement in capital markets. On reserve assets, redemption, and insolvency proceedings, it sets out the shared views of the two governments.

First, the statement says that stablecoins offered for use as money should be fully backed, at least one-to-one, by high-quality liquid assets. Each country's regime should clearly define the scope of eligible reserve assets (assets held to meet redemptions). Reserve assets should be segregated from the issuer's own funds and protected for holders. Issuers should redeem in a timely manner and clearly disclose the nature of holders' rights.

The two governments said they would develop frameworks, consistent with their respective laws, so that if an issuer becomes insolvent (enters bankruptcy or resolution proceedings), holders have a clear claim on the reserve assets, with priority over other creditors. The statement adds that appropriate cooperation between countries should also be considered in cross-border insolvency proceedings.

Exploring entry pathways rather than mutual recognition

The last item of the statement is that, subject to each country's laws and procedures, the two governments will "explore" clear pathways for stablecoins issued in one country to enter the other's market. The statement does not contain an agreement on mutual recognition (accepting the other country's regulation and authorization as if they were one's own).

On the U.S. side, the entry point is Section 18 of the GENIUS Act (the U.S. stablecoin law), enacted on July 18, 2025. For a foreign issuer to be granted an exception from the Act's prohibitions on issuance and sale, several conditions must be met. These include a determination by the Secretary of the Treasury that the home country's regime is comparable to the Act, and registration with the Office of the Comptroller of the Currency (OCC). The determination requires a recommendation from all members of the Stablecoin Certification Review Committee other than the Secretary of the Treasury, and the reasons for it must be published in the Federal Register before it takes effect. The Secretary of the Treasury may enter into reciprocal arrangements with countries that have comparable regimes, and the Act recommends that these arrangements be concluded within two years of enactment.

The same section requires reserves sufficient to meet the liquidity needs of U.S. customers to be held at U.S. financial institutions, with an exception where a reciprocal arrangement permits otherwise. The joint statement says the two governments will avoid prudential measures that require resources to be excessively ring-fenced within their own borders. Where the line for "comparable" is drawn is the core question for this pathway.

Timelines in London and Washington, 2027 and 2028

The UK regime moved ahead of the recommendations. On June 22, the Bank of England published a policy statement and draft rules on systemic stablecoins (stablecoins in wide enough use to have a significant effect on financial stability). It raised the cap on interest-bearing short-term UK government debt within reserve assets from 60% to 70%, with the remainder to be held as deposits at the central bank. Instead of limits on individual holdings, it sets a temporary cap of GBP 40 billion on the total issuance of each stablecoin. The plan is to take comments until September 22, finalize the rules by the end of the year, and have regulated stablecoins operating in the UK from 2027.

Uses that are not systemic, such as crypto-asset trading, are supervised by the FCA alone. On June 30, the FCA published final crypto-asset rules covering stablecoin issuance, among other activities. The new regime is scheduled to take effect on October 25, 2027. The window for authorization applications opened on September 30, 2026 and runs until February 28, 2027.

The U.S. GENIUS Act takes effect on the earlier of 18 months after enactment or 120 days after the final implementing regulations are issued. A proposed rule issued by the U.S. Department of the Treasury on August 18 states that the federal stablecoin framework has not yet taken effect. Comments are accepted until October 19. According to the same document, from July 18, 2028, digital asset service providers may sell in the United States only stablecoins from permitted issuers or from foreign issuers that meet the Section 18 requirements.

On July 8, the 13th meeting of the U.S.-UK Financial Regulatory Working Group was held in London, and the U.S. side reported on the status of GENIUS Act implementation. The Taskforce is to report its recommendations to the two finance ministries through this Working Group. The Working Group's next meeting is scheduled for early 2027.

Three questions for becoming a comparable counterpart

As of reports on September 22, the proposed Digital Asset Basic Act (working title), a bill under discussion that would cover won-denominated stablecoins, had not been submitted to the National Assembly, as the government bill was still at the stage of coordinating detailed issues. The Financial Services Commission (FSC), Korea's financial regulator, was reported to be aiming for discussion at the legislative subcommittee of the National Policy Committee of the National Assembly in November. As the law takes shape, three questions can be considered in light of the U.S.-UK joint statement.

The first is the benchmark for each item to be compared. The joint statement sets out the two governments' shared views on the scope of reserve assets, segregation, timely redemption, and priority claims in insolvency. The starting point is which outcome a won stablecoin regime takes as its benchmark for each of these items.

The second is where reserve assets are held. U.S. law allows an exception, through reciprocal arrangements, to the requirement that reserves for U.S. customers be held in the United States, and the two governments said they would avoid excessively ring-fencing resources within their own borders. For a won stablecoin used across borders, the question is how much of the reserve assets should be held, in which country and at which institutions, to satisfy both user protection and cross-border use.

The third is a venue for testing market infrastructure issues. The two countries placed settlement finality and the acceptance of tokenized MMFs and similar instruments as collateral on the common agenda for regulators, and stated their intention to cooperate, on a one-year basis, with a private sector-led testing group. In Korea, it remains open who will test such use cases, in what way, and how the results will be shared with regulators.

Comparability is not something a country obtains by declaring it on its own. Under the GENIUS Act, that determination is made by the U.S. Secretary of the Treasury on the recommendation of the review committee.