This article explains a practical question for cross-border users: which set of stablecoin rules should you pay attention to? You need to understand the differences between the two frameworks before making a judgment.
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If you trade between the US and the EU, you may have noticed that USDC works on both sides — but the underlying rules are different. One framework requires issuers to hold reserves mainly in banks, while the other focuses on government bonds. And neither side recognizes the other's licenses.
For cross-border users, the core principle is simple: follow the rules where you use the stablecoin. But if you want to use it in both places, you need to meet compliance requirements on both sides.
Core Differences Between the Two Frameworks
The US GENIUS Act and the EU's MiCA both require stablecoins to maintain 1:1 reserves and redeem at face value. Neither allows issuers to pay interest to holders. But in practice, the differences are clear:
Reserve composition is different: The GENIUS Act limits eligible reserve assets to three categories: US dollar cash, US Treasury securities with remaining maturities of 93 days or less, and overnight repurchase agreements backed by US Treasuries. MiCA, by contrast, requires significant issuers to hold at least 60% of reserves as deposits in EU banks, with the remaining 40% in instruments that mature daily.
No mutual recognition: As of June 2026, there is no equivalence agreement between MiCA and the GENIUS Act. An institution with a MiCA license cannot operate in the US market based on EU authorization, and vice versa. Mid-sized operators that maintain separate compliance structures in both jurisdictions face additional operating costs of roughly $200,000 to $500,000 per year.
Different regulatory scope: The GENIUS Act only covers payment stablecoins, making it narrower in scope. MiCA covers a much broader range, including crypto-asset service providers, market abuse rules, and environmental impact disclosures.
Which Framework Should Cross-Border Users Follow?
Case A: You use or hold stablecoins in the US
You need to follow the GENIUS Act framework. Non-US users who hold US-issued stablecoins such as USDC or PYUSD are still covered by the Act's legal order framework and reserve protections. However, foreign issuers entering the US market need the US Treasury to determine that their home country's regulatory system is "comparable" and complete registration — as of June 2026, no such determination is in effect.
Case B: You use or hold stablecoins in the EU
You need to follow the MiCA framework. Issuers of MiCA-compliant stablecoins must establish a legal entity in the EU and obtain authorization. Non-significant issuers face lighter compliance obligations, but in principle they must follow the same structural requirements.
Case C: You trade or hold in both regions
You need to satisfy both sets of requirements at the same time. A single reserve portfolio cannot meet both regimes — because the eligible asset categories are different on each side. Issuers must maintain separate asset pools in each jurisdiction.
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Practical Steps
[What to do]: Based on your usage scenario, determine which regulatory framework you need to pay attention to.
[How to do it]:
Open the trading platform you use most often, go to the stablecoin product page, and check whether it is labeled as "GENIUS-regulated" or "MiCA-regulated."
If you mainly trade on US platforms, prioritize tracking the status of GENIUS-compliant stablecoins like USDC and PYUSD.
If you mainly trade on EU platforms, check whether the platform has already delisted non-MiCA-compliant stablecoins — the transition period ended in June 2025.
[Completion standard]: You can clearly state which jurisdiction regulates the stablecoins you hold, and what the core reserve requirements are under that framework.
Risk reminder: The US Treasury has a "reciprocal recognition" clause, which in theory could recognize MiCA as a "comparable framework" in the future. But as of mid-2026, there is still no concrete timeline. Until then, the two markets operate independently. Do not assume that compliance on one side equals compliance on the other.
How to verify completion: Check the announcements from your usual trading platforms to confirm their plans for stablecoin compliance support. If you have accounts in both regions, check separately whether each platform has issued restriction notices for stablecoins that are not compliant locally.
Next step: If you hold USDT on an EU platform, pay attention to whether the platform will restrict or delist the asset due to MiCA compliance requirements — Tether is currently not issued by a US-licensed entity, nor has it received an equivalence determination from the US Treasury. Understand the platform's conversion options in advance to avoid being caught off guard.
