Stablecoin regulation in the UK, Singapore and Hong Kong compared

On November 1, 2026, Hong Kong licenses stablecoin issuers under a law in force since August 1, 2025. The UK has final rules that apply from October 25, 2027. Singapore runs a 2023 policy while its law is in draft. All three regulate the issuer first, so payments companies feel them through the coins they can offer.

The US and EU sides are in the GENIUS Act explainer and the MiCA explainer. For news, see US and UK alignment, Singapore as a crypto hub and 3.3 million wallets in Hong Kong.

Where do the three regimes stand on November 1, 2026?

Lumx runs EUR and GBP through a banking partner. It holds no HKMA, MAS or FCA licence: it onboards customers from the UK, Singapore and Hong Kong by reverse solicitation, meaning the customer approaches Lumx and Lumx does not market there. The product section below has the detail.

United Kingdom: final rules, in force from October 25, 2027

The FCA's overview of its cryptoasset policy statements says the full scope of regulated activities applies from October 25, 2027. The stablecoin rules are in PS26/10, dated June 2026. A UK-issued qualifying stablecoin must be fully backed and redeemable at par, with backing assets on statutory trust.

The Bank of England adds a second layer for the largest coins. In its policy statement of June 22, 2026, it allows up to 70% of backing assets in short-term UK government debt, the rest in central bank deposits, and replaces holding limits with an issuance guardrail of £40 billion per systemic coin. HM Treasury decides which coins are systemic. The final Code of Practice is due by the end of 2026.

The date to watch is the FCA's application window, open from September 30, 2026 to February 28, 2027. Existing registrations do not convert, so a firm already registered under the Money Laundering Regulations or authorised under the Payment Services Regulations or Electronic Money Regulations must still apply if it is in scope. If you are in scope, file inside the window.

On the Lumx side, GBP runs through a banking partner over Faster Payments (the UK's real-time bank transfer network), which the docs list on the Coverage page with instant settlement.

Singapore: policy since 2023, law still in consultation

MAS finalised its single-currency stablecoin framework (MAS-SCS) when it published its response to consultation feedback on August 15, 2023. It applies to single-currency stablecoins issued in Singapore and pegged to the Singapore dollar or any G10 currency. Only licensed issuers may call their coins "MAS-regulated stablecoins". Every other stablecoin is a digital payment token (DPT), with the consumer safeguards that apply to DPTs.

On September 1, 2026, MAS published a consultation paper on amendments to the Payment Services Act 2019 that would give the framework legal force, with comments due by October 16, 2026. The paper keeps the 2023 core of value stability, capital, redemption at par and disclosure, and adds joint issuance with a foreign issuer, recognition of some foreign coins for wholesale use, an interest ban, stress testing and wind-down plans. MAS media releases through October 29, 2026 contain no outcome, so each of these is still a proposal. Do not plan a launch on the draft law.

The Lumx docs list Singapore among the supported countries, where customers are onboarded under standard KYC (know your customer, the verification of an individual) and KYB (know your business, the verification of a company and its owners), though a supported country does not mean a local rail exists. Lumx serves these customers by reverse solicitation, without a local licence. The Singapore-only answer is in stablecoin regulation in Singapore under MAS.

Hong Kong: licensing is live and two issuers hold licences

The Stablecoins Ordinance (Cap. 656) took effect on August 1, 2025 (Cap. 656 on the Hong Kong e-Legislation site). Issuing a fiat-referenced stablecoin in Hong Kong is a regulated activity that needs an HKMA licence, as does issuing abroad a coin that references the Hong Kong dollar. On April 10, 2026, the HKMA granted the first licences to Anchorpoint Financial Limited and The Hongkong and Shanghai Banking Corporation Limited, and the HKMA's complaint-contact list of July 17, 2026 still shows those two.

The HKMA's explanatory note on licensing sets paid-up capital of at least HKD 25 million or equivalent approved resources, a segregated reserve pool worth at least the par value of coins outstanding, and redemption at par, normally processed within one business day. The register on the HKMA's stablecoin issuers page is where to check a claim that a coin is licensed.

Check the register before accepting a coin from a Hong Kong counterparty. Hong Kong is a separate question from mainland China, where PBoC Yinfa [2026] No. 42 of February 6, 2026 bars foreign crypto services to people there, so those suppliers get USD by SWIFT. For a Hong Kong counterparty, Lumx pays USDT or USDC by a transfer to an external wallet, or pays USD by SWIFT. The Hong Kong guide is the HKMA stablecoin license explained.

Who can issue a stablecoin in each place, and on what terms?

The three regimes ask the issuer for the same things and differ in how far each is written down today.

Issuer requirements, from FCA PS26/10, the MAS consultation paper of September 1, 2026 and the HKMA licensing guidance.

On capital and backing, the UK requires full backing held on statutory trust, with up to 5% excess allowed, and the issuer's own-funds requirement sits in the FCA's prudential rules for issuers. PS26/10 mentions it only in its cost estimates, so no figure is given here. Hong Kong requires paid-up capital of at least HKD 25 million or equivalent approved resources, and a segregated pool worth at least par in the referenced asset, with qualified custodians. The MAS capital and reserve detail was not read, so Singapore is left out of this comparison.

The UK and Hong Kong already write the interest ban into final texts: PS26/10 for backing-asset income, and the HKMA's supervision guideline, which applies Schedule 2 of the Ordinance.

Lumx does not issue a stablecoin. Its wallets hold USDC and USDT, issued by Circle and Tether.

How is a foreign stablecoin such as USDC or USDT treated?

None of the three regimes bans a coin because it was issued elsewhere. Each asks who needs authorisation.

A business that only holds and pays in USDC or USDT is not the target of these rules. The firm that moves, holds or sells the coin for it is.

At Lumx, a payout debits the wallet of an onboarded customer to a destination registered under that customer, and the docs bar passing funds for parties Lumx cannot see (the Nested Payments page).

What a payments company has to hold in each place

The regimes license the activity, so one company can need several permissions. This table reports the texts and is not a legal opinion.

Permissions by activity, from the FCA overview, FCA guidance FG26/7 and the HKMA licensing guidance.

Singapore is not in this table. Issuing needs a MAS licence once the law passes, but the rules for holding and dealing sit in the digital payment token licensing under the Payment Services Act 2019, which this post did not read. Ask counsel there before you hold client coins.

A firm that classes itself as a VASP (virtual asset service provider, the FATF term) should treat its row as a starting question for counsel. The VASP explainer covers it.

Lumx onboards stablecoin issuers and wallet providers as high-risk customers, with disclosure and Enhanced Due Diligence, as the docs list. A licence in one of these places does not skip that review.

I tell payments teams to read these regimes by the activity they perform and not by the country on the letterhead. Before a GBP, SGD or HKD flow is priced, I want three answers on one page: which stablecoin the money moves in, who issued it and under which regime, and which licensed entity handles each step. A team that can name the coin and not the licensed entity behind a step has a gap that a regulator or banking partner finds before the first payment.

When this comparison is the wrong guide

Use another source to issue a stablecoin here, because application detail needs the regulator's forms and counsel. It is also the wrong guide for mainland China, Japan or South Korea, and for fixing a launch date, because MAS's outcome and the Bank of England's final Code can move the table within weeks.

What GBP and Hong Kong payments look like with Lumx

Lumx is stablecoin payments infrastructure for businesses that move money between Latin America and the rest of the world: one API to collect, hold, convert, and pay out in BRL, MXN, COP, USD, EUR, and GBP or in USDC and USDT, over local rails such as PIX, SPEI, PSE, Bre-B, ACH, FEDWIRE, SEPA, and Faster Payments, with SWIFT and on-behalf-of payments and collections (POBO and COBO) in USD, EUR, and GBP, plus named virtual accounts, custodial wallets, and KYB/KYC built in.

For a GBP payout, the customer is onboarded, funds a wallet in USDC or USDT, and the off-ramp sends pounds to a registered destination over Faster Payments. Faster Payments runs around the clock at up to £1 million per payment, and the docs show the customer as sender of record. The USDC to GBP page shows the corridor, and the coverage page lists the rails and settlement times (as of November 2026).

A Hong Kong company is a standard-KYB customer and can be a paying customer. For a Hong Kong counterparty there are two paths. USD goes by SWIFT in one to five business days, with a UETR and MT103 confirmation on every payout. Stablecoin goes by a transfer from the wallet to the counterparty's external wallet address. The operator map and supported countries show where customers are onboarded.

Lumx handles the KYB, the verification of each destination and the conversion inside the API, as the global payments page shows. On a stablecoin corridor into Hong Kong, the regimes above decide which coin the receiving side can use, and Lumx moves the money.

Methodology and sources

On November 1, 2026, the UK was read from the FCA overview of its cryptoasset policy statements, PS26/10 and guidance FG26/7, and from the Bank of England policy statement of June 22, 2026. Hong Kong was read from the HKMA press releases of April 10, 2026 and July 29, 2025, its licensing note, its supervision guideline and the licensee complaint-contact list updated July 17, 2026. The MAS site returned a maintenance wall to direct requests, so the MAS media release of September 1, 2026 was read through a text-extraction service that serves the same page, and it is cited by name and date without a link. The 2023 MAS response paper was not read and is cited as the 2026 release describes it. Singapore's DPT licensing conditions and the MAS capital and reserve figures were not read, which is why Singapore is absent from the capital, backing and holding comparisons. Lumx product facts come from the docs.lumx.io pages on coverage, supported countries, rail cut-offs, sender of record, wallets, nested payments and prohibited activities, read the same day.

Verified on November 1, 2026. Operational context, not legal, tax, or investment advice. FCA cryptoasset regime and PS26/10 checked against fca.org.uk on November 1, 2026. Bank of England policy statement of June 22, 2026 checked against bankofengland.co.uk on November 1, 2026. Stablecoins Ordinance (Cap. 656) guidance checked against hkma.gov.hk on November 1, 2026. MAS media release of September 1, 2026 on legislative amendments for stablecoins read on mas.gov.sg on November 1, 2026.

Cover photo: Margaret Giatras on Unsplash.