US and UK Treasuries align stablecoin, tokenization rules
The US and UK have published a joint regulatory roadmap for stablecoins and tokenized assets, a non-binding effort to coordinate transatlantic capital markets as both nations race to catch up with the EU's MiCA framework.
The US and UK Treasuries published 10 joint recommendations on Tuesday to align their regulation of stablecoins and tokenized assets. Five of the non-binding measures target digital assets, while the remaining five address traditional capital markets. The guidance stems from the Transatlantic Taskforce for Markets of the Future, established by Treasury Secretary Scott Bessent and Chancellor Rachel Reeves during President Trump’s state visit to the UK in September 2025.
For market professionals, the taskforce’s focus on market infrastructure carries the most immediate significance. Regulators including the SEC, CFTC, FCA and Bank of England are directed to find common ground on how tokenized securities achieve settlement finality. The framework also explicitly explores whether stablecoins and tokenized money market funds can be accepted as collateral at clearing houses, a critical step for institutional adoption.
On stablecoins, the two governments endorsed a "multi-money ecosystem" where digital currencies coexist with traditional forms. They backed a requirement that payment stablecoins maintain at least a one-to-one backing by high-quality liquid assets, directly echoing the US GENIUS Act signed last year. Additionally, the taskforce called for a technology-neutral review of how the Basel Committee treats banks' crypto exposures.
The alignment effort is fundamentally designed to help London and New York close the regulatory gap on the European Union. The EU’s MiCA rules have been fully in force since late 2024 and are scheduled for revision in 2027. Meanwhile, the UK’s domestic cryptoasset regime is due to take effect in October 2027.
Despite the shared direction, the roadmap stops short of granting mutual recognition. A stablecoin licensed in either jurisdiction will still need to navigate the other country's specific regulatory approval process to operate cross-border. To address practical hurdles, a newly proposed private-sector group will spend the next year testing cross-border tokenization use cases.
Industry participants reacted positively to the transatlantic coordination. Katie Harries, Coinbase’s head of policy for Europe, called the recommendations a “critical moment for transatlantic cooperation” and highlighted the opportunity to "reimagine global capital markets through tokenisation." The guidance builds on remarks by UK Economic Secretary Lucy Rigby, who has signaled an ambition to "minimize frictions" between the two markets.
