Crypto groups in the UK have rallied against the Bank of England’s proposal to restrict stablecoin ownership in the country, saying it would put the nation at a disadvantage and be costly and unwieldy to implement.
The Financial Times on Monday (September 15) reported that the BOE plans to impose ownership limits of £10,000 to £20,000 for individuals and £10mn for businesses on all systemic stablecoins. The central bank has justified this move based on the risks posed to the banking system in the absence of crypto regulation.
What are stablecoins, and how are they different from other cryptocurrencies? What risks have regulators flagged regarding stablecoins?
Stablecoins are a form of cryptocurrency designed to maintain a stable value in relation to a certain asset. Unlike Bitcoin and other such cryptocurrencies that experience price volatility, stablecoins are typically pegged to a traditional currency such as the US dollar.
Stablecoins are not generally used for transactional purposes, but instead by crypto investors to park their profits without converting them back into real money. They enable cheap and fast transactions without the need for intermediaries in traditional payment mechanisms. Their ownership is simultaneously registered in digital ledgers, eliminating the costs and lengthy processing times involved with traditional cross-border transitions.
This April, Standard Chartered Bank estimated that the size of the stablecoins market could increase tenfold to $2 trillion by 2028.
And what are the types of stablecoins?
There are primarily four types of stablecoins, of which three are pegged to a different asset, such as fiat currency, meaning the government-issued currency authorised as legal tender; commodities such as gold, silver or oil; or even cryptocurrencies.
The fourth variant, algorithmic stablecoins, may be pegged to an asset, but are typically regulated through a computerised algorithm. This is similar to a currency peg, with more coins being generated if the stablecoin trades above its pegged value to cause a price reduction. Similarly, some coins may be taken out of circulation if the stablecoin trades below the peg, to induce demand and cause the price to increase.
While dozens of stablecoins are widely used, the most popular of these is Tether, which is widely exchanged for several cryptocurrencies. A user pays $1 for Tether, which, in theory, is held in safe assets such as cash or US Treasury bills.
What are the risks associated with stablecoins?
Stablecoins presently pose a threat to financial stability. There remains an ever-present ‘run’ risk, meaning a risk of mass withdrawal of holdings simultaneously, akin to a bank run during an economic crisis.
This has a precedent. On May 11, 2022, the stablecoin TerraUSD (UST) crashed from its intended 1-to-1 peg to the US dollar by more than 60%, all but eliminating its dollar peg. Being an algorithmic stablecoin, the UST was not directly pegged to the dollar but through the related Luna token. According to a Bloomberg report, investors could (in theory) exchange one unit of the token, regardless of its current trading price, for $1 worth of Luna. This trade helped UST maintain its value at close to $1 and retain its status as the biggest algorithmic stablecoin by market value at the time.
In its latest annual economic report, the Bank for International Settlements (BIS), which effectively operates as the central bank for central banks worldwide, has identified three issues with stablecoins:
Singleness – Stablecoins traded in secondary markets, such as stock exchanges, usually have a slight deviation from the fiat currency they are pegged to, and may not be pegged at par.
Elasticity – Stablecoins fail the test of elasticity, which implies adjusting the circulation of stablecoins to meet the market demand. The supply of stablecoins that can be issued depends on the issuer’s balance sheet, which cannot be expanded at will, unless they have the requisite cash or assets to back them. Therefore, any additional supply would need to be fully paid for upfront by its holders, unlike banks, which can expand (and contract) their balance sheets within regulatory limits. Thus, the system cannot expand quickly to provide additional liquidity in case of high demand.
Integrity – The free trading of stablecoins across borders, on different exchanges and into self-hosted wallets makes them vulnerable to the risks of non-compliance with Know Your Customer (KYC) norms. This raises the risks of money laundering, terror funding and other suspicious activity.
The Bank of England noted that stablecoin tokens could weaken the banking system by draining it of deposits. Sasha Mills, the executive director for financial market infrastructure, said in a speech in July that the limits would “mitigate financial stability risks stemming from large and rapid outflows of deposits from the banking sector — for example sudden drops in the provision of credit to businesses and households — and risks posed by newly recognised systemic payment systems as they are scaling up”.
It said that its current move to place transactional limits may be a “transitional” measure until the financial system adjusts to the widespread use of digital money. The bank will publish a consultation regarding its updated plans for stablecoin regulation later this year, FT reported.
How have other countries treated stablecoins?
US – GENIUS ACT
This July, US President Donald Trump signed the GENIUS Act into law, which introduced a regulatory framework for stablecoins. The move signalled Trump’s renewed stance on crypto, having told Fox Business in 2021 that cryptocurrency such as Bitcoin “seems like a scam.” (He has since moved to launch the $TRUMP memecoin, whose prices are determined by internet popularity. In March, World Liberty Financial, the Trump family’s crypto venture, launched the USD1 stablecoin, which is pegged to the US dollar and backed by a reserve of cash-like assets.)
The Guiding and Establishing National Innovation for US Stablecoins Act, or the GENIUS Act, is the country’s first major regulatory legislation and contains three significant provisions –
EUROPEAN UNION – MiCA
The European Union’s Markets in Crypto-Assets Regulation (MiCA), passed in December 2024, addresses all e-money tokens (EMT), which are digital tokens backed by a single fiat currency, and asset-referenced tokens (ART), meaning a basket of assets, including physical assets and cryptocurrencies. While MiCA does not specifically focus on stablecoins, it mandates that only authorised e-money institutions or credit institutions can issue an EMT. On the other hand, ART issuers must be EU-based and authorised by regulators.
HONG KONG – STABLECOIN ORDINANCE
The stablecoin ordinance was passed in May 2025 in Hong Kong. It requires all stablecoin issuers backed by the Hong Kong dollar to obtain a license from the Hong Kong Monetary Authority. All stablecoins must be backed by high-quality, liquid reserve assets, with the market value of the reserve pool at par with the value of the stablecoins in circulation. Most importantly, every issuer must implement measures against money laundering and financing of terrorism, as well as regular audits and disclosure.