US and UK Propose Joint Framework to Harmonize Stablecoin and Tokenization Regulations

In brief

  • The U.S. Treasury and the UK Treasury have issued ten joint recommendations to harmonize regulations concerning stablecoins, tokenized assets, and capital markets, with five targeting digital assets.
  • These recommendations, issued by a taskforce created during President Trump’s 2025 UK state visit, are non‑binding and outline a shared direction, including the establishment of a private‑sector group to trial cross‑border tokenization and a joint statement endorsing stablecoins.
  • Coinbase welcomed the plan, describing it as a critical moment for transatlantic cooperation.

The United States and United Kingdom have presented a joint roadmap to align the regulation of stablecoins, tokenized assets, and digital money, representing a coordinated effort by two of the world’s largest financial centres to facilitate the cross‑Atlantic flow of blockchain‑based finance.

The ten recommendations were published on Tuesday by HM Treasury and the U.S. Treasury, originating from the Transatlantic Taskforce for Markets of the Future, which Chancellor Rachel Reeves and Treasury Secretary Scott Bessent established during President Trump’s September 2025 UK state visit.

Five of the recommendations pertain to digital assets, while the remainder address traditional capital markets; none constitute binding rules, leaving each jurisdiction to finalize its own regulatory process in line with the common direction.

Stablecoins and tokenization

Regarding digital assets, the taskforce urges regulators, the Bank of England, the FCA, the SEC, and the CFTC to develop common approaches to tokenized assets, such as the settlement finality of tokenized securities and the use of stablecoins and tokenized money‑market funds as collateral at clearing houses. It proposes a private‑sector‑led group to test cross‑border tokenization use cases over a one‑year period, and envisions a “multi‑money ecosystem” where stablecoins, tokenized bank deposits, and other digital currencies coexist.

In addition, the two governments are drafting a joint statement on stablecoins that supports a dynamic cross‑border market and asserts that payment stablecoins must be fully backed, on a one‑to‑one basis, by high‑quality liquid assets—principles that echo the U.S. GENIUS Act, the federal stablecoin law enacted last year. A fifth recommendation calls on both sides to advocate a technology‑neutral review of the Basel Committee’s treatment of banks’ crypto exposures.

This alignment effort coincides with each country’s effort to build out its own regulatory regime. The United States is implementing the GENIUS Act ahead of its 2027 effective date, while the United Kingdom’s cryptoasset regime is slated for implementation in October 2027. Both aim to keep pace with the European Union, whose MiCA framework has been fully in force since the end of 2024 and is scheduled for revision in 2027. The recommendations do not provide mutual recognition; a stablecoin licensed in one jurisdiction must still satisfy the other jurisdiction’s requirements to operate there.

Crypto firms welcomed the direction. Katie Harries, Coinbase’s head of policy for Europe, described the recommendations as a critical moment for transatlantic cooperation, highlighting the chance for the two financial centres to reimagine global capital markets through tokenisation.

In the United Kingdom, the recommendations reinforce an ambition to minimise frictions between the two countries, as articulated by Economic Secretary to the Treasury Lucy Rigby in May, who suggested that alignment may take the form of reciprocal recognition or regulatory harmonisation.

At that time, Rigby noted that digital assets hold the potential for a complete transformation of the country’s markets, as the government advances stablecoin rules, an FCA‑run stablecoin sandbox, and a consultation on a unified framework for traditional and tokenised payments.

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