International Regulatory Trends on Stablecoins and Implications for Japanese Law — Legal and Practical Issues of Trust-Type Electronic Payment Instruments Based on the U.S. GENIUS Act and the EU MiCA Regulation (Part I)

December 2025 Expert Jack Jia
In July of this year, the “GENIUS Act” was enacted in the United States, marking a significant advancement in the regulatory frameworks for stablecoins across Japan, the European Union, and the United States. As each jurisdiction has developed its own framework through distinct approaches, an environment conducive to the entry of financial institutions and technology companies is gradually emerging. This paper organizes recent international regulatory developments relating to stablecoins and examines their implications for Japan’s pioneering framework. Part I provides a comparative overview of the regulatory architectures in the United States, Europe, and Japan, while Part II addresses issues concerning supervisory implementation and challenges for private-sector deployment.
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Introduction

We first organize the international regulatory trends surrounding stablecoins. In Japan, under the “Amended Payment Services Act” that took effect on June 1, 2023, stablecoins backed by legal tender were defined as “electronic payment instruments,” enabling their issuance and circulation domestically.1 By contrast, looking overseas, the European Unionʼs Markets in Crypto-Assets Regulation (MiCA) ̶ specifically Titles III and IV, which came into effect on June 30, 2024 ̶ requires stablecoin issuers to obtain an EU license and to comply with strict reserve requirements and redemption-risk management standards.2 In the United States, the GENIUS Act was enacted on July 18, 2025, finally establishing a clear, stringent federal licensing and supervisory framework for stablecoins and their issuers.3

Next, we organize recent key developments in Japanese industry. On March 4, 2025, SBI VC Trade wae registered by the Financial Services Agency as Japanʼs first “Electronic Payment Instruments Service Providers,” making it possible to handle USDC (a foreign electronic payment instrument) as the first stablecoin to be listed in Japan.4 Furthermore, on August 18, 2025, JPYC Inc. registered as a “Funds Transfer Service Provider,” making it possible to issue Japanʼs first yen-denominated stablecoin.5 That said, the USDC handled by SBI VC Trade is subject to upper limits based on supervisory guidelines̶ such as “JPY 1 million per transfer” and “JPY 1 million per person under the amount managed by the operator”̶and the company imposes a “JPY 1 million per transaction” cap for both buying/selling and withdrawals. In addition, issuance and redemption by JPYC (a Type II funds transfer service provider) are, as a matter of law, restricted to “JPY 1 million per day.”6 Unlike USDT7 and USDC8 in overseas markets, which have no limits on issuance and redemption, no unrestricted stablecoin of that kind currently exists in Japan. In the future, stablecoins issued by banks, trust banks, or trust companies may no longer be subject to this ¥1 million cap.

When discussing recent developments in Japanʼs industrial sector, it is also necessary to mention Progmat. Progmat is……

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