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Stablecoin Legislation—Reserve Rules Become Law

When reserve contents become legal requirements instead of issuer promises, which risks shrink and which grow?

Checked in September 2026. This is event-layer content; read “Expiring Details” at the end first.

What Happened

DateEvent
June 2024The stablecoin provisions of the EU's unified Crypto-asset regulatory framework began applying
July 2025The United States signed its first federal payment-stablecoin law: licensed issuance, one-to-one reserves in liquid assets such as cash and short-term Treasuries, regular reserve disclosure, and no interest paid by issuers to holders
August 2025Hong Kong's stablecoin-issuer licensing regime took effect

Analyze with Course Models

From “Trust Me” to “The Law Requires Me”

Chapter 13 divides stablecoins into reserves, redeemability, and priority after failure. Before dedicated laws, these were issuer promises. Its cases showed gaps between promises and reality.

Legislation turns two aspects into rules: permitted reserve assets must be highly liquid, and disclosure frequency is specified. This directly addresses Chapter 13's noncash-reserve risks.

Risks That Remain

Reuse Chapter 1's table:

Before legislationAfter legislation
Ledger keeperIssuer, with balances visible onchainUnchanged
Reserve contentsIssuer discretionLegally limited categories and regular disclosure
Settlement timeMinutes onchainUnchanged
Contact after failureDepends on termsRegulator and explicit repayment priority, but still no deposit insurance

Three risks remain: failing reserve banks and custodians, as in Chapter 13's bank-run transmission; freezing, which regulated issuers must support when required; and stablecoins issued outside the law's coverage.

Where Does the Interest Go?

Issuers cannot pay holders interest, but short-term Treasury reserves generate it. Chapter 26 asks who receives this revenue? The issuer. Holders get non-interest-bearing digital dollars; issuers receive reserve interest. This makes issuance attractive and was a major legislative dispute.

Retain the Mechanism

  • Most stablecoin risk sits offchain in reserves, custody, and law. Legislation changes that layer while onchain accounting and settlement remain unchanged.
  • Compliance and freezing are linked: greater regulation requires the ability to freeze when directed.
  • Issuers retain reserve yield on non-interest-bearing stablecoins. Asking where interest goes explains the business.

The Eighteen Questions

9
Who bears the risk?

Reserve-asset-category risk declines substantially after legislation. Custodian-bank risk, freezing risk, and risks of out-of-scope issuers remain.

6
Where does revenue come from?

Reserve interest and, for some issuers, minting and redemption fees.

Verify Independently

Hands onRead a stablecoin reserve reportIssuer reserve-disclosure pagesFree; read-only

Find the latest reserve report, recording its date and reporting institution.

List reserves by category: cash, short-term Treasuries, repos, and others. Record proportions and any legally prohibited category.

Find redemption terms: eligible direct redeemers, minimum amount, and delivery time. Compare Chapter 13's thought experiment.

Expiring Details

  • Laws continue to be introduced and revised. Implementation rules and effective dates may have changed.
  • Licenses and reserve composition must be checked against current official disclosures.

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