"US and EU Align on Stablecoin Rules Despite Divergent Goals, Sparking Regulatory Tensions"

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Tuesday, Dec 2, 2025 2:57 am ET2min read
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- Swedish Riksbank highlights growing US-EU regulatory alignment on stablecoins despite divergent legal frameworks.

- Both regions restrict stablecoin access to central bank systems, with ECB limiting non-bank collateral use despite MiCA allowances.

- Deutsche Börse's EURAU integration exemplifies Europe's push for digital finance, aligning with MiCA's liquidity goals.

- Risks include deposit siphoning from banks and unstable private liquidity models, prompting Fed's non-interest-bearing account proposals.

- Riksbank forecasts gradual convergence as adoption grows, though fragmented regulations may delay global framework establishment.

The Swedish Central Bank's recent report has underscored a notable trend in global stablecoin regulation: [despite divergent legal frameworks](https://en.bitcoinsistemi.com/stablecoin-report-from-the-swedish-central-bank-europe-and-the-us-are-making-similar-regulations-here-are-the-details/), the United States and Europe are increasingly aligning in their policy approaches. This convergence, outlined in the Riksbank's analysis, focuses on three critical dimensions-access to central bank settlement systems, the use of central bank reserves as collateral, and liquidity support for stablecoin issuers. While both regions technically permit the use of central bank reserves, practical restrictions remain, such as [the European Central Bank's (ECB) limited allowance](https://www.panewslab.com/en/articles/f87bbbbe-4c83-4a85-ba36-46b0c8165527) for non-bank payment institutions to hold central bank balances for transaction flows without using them as stablecoin backing.

Meanwhile, European adoption of euro-pegged stablecoins is gaining momentum, driven by the Markets in Crypto-Assets (MiCA) framework. Deutsche Börse, a key player in this shift, [announced plans to integrate](https://www.coinglass.com/news/757565) the EURAU stablecoin issued by AllUnity into its financial infrastructure, joining prior partnerships with Circle's EURC and Societe Generale-Forge's EURCV. This move reflects a broader strategy to bridge traditional finance and digital assets, with Deutsche Börse's executive Stephanie Eckermann emphasizing the need to "build a seamless bridge between the established financial world and the future of digital assets." The integration aligns with MiCA's goals to digitize European markets and enhance liquidity processes, though stablecoin adoption remains limited in the region [as the report notes](https://www.coinglass.com/news/757565).

The Riksbank's report highlights regulatory parallels between the US and Europe. In the US, the proposed GENIUS Act aims to expand stablecoin reserves to bolster dollar dominance, while Europe's MiCA framework imposes stricter controls to preserve monetary independence. Both regions, however, [restrict stablecoin issuers from full access](https://coinedition.com/why-your-mortgage-rate-could-depend-on-tether-and-circles-growth/) to central bank settlement systems. The ECB's cautious stance is evident in its refusal to permit stablecoins to use central bank reserves as collateral, despite legal allowances under MiCA. This creates a tension between regulatory intent and practical implementation, as seen in the ECB's recent decision to allow non-bank payment institutions limited central bank account balances for payment flows [according to recent analysis](https://www.ledgerinsights.com/riksbank-explores-different-central-bank-approaches-to-stablecoins/).

Risks associated with stablecoin growth are also under scrutiny. The Riksbank warns that widespread adoption could siphon deposits from commercial banks, potentially tightening credit conditions and raising borrowing costs for households and businesses. This risk is amplified by stablecoins' lack of deposit insurance and their reliance on private liquidity models [as noted in the report](https://coinedition.com/why-your-mortgage-rate-could-depend-on-tether-and-circles-growth/). Additionally, fire-sale risks and inconsistent redemption practices pose challenges for regulators. In the US, the Federal Reserve's proposed policy changes would introduce non-interest-bearing accounts with strict caps, maintaining tight control over liquidity access [according to market analysis](https://coinedition.com/why-your-mortgage-rate-could-depend-on-tether-and-circles-growth/).

Looking ahead, the Riksbank anticipates increased policy alignment as stablecoin adoption accelerates. Cross-border payment innovations and institutional-grade solutions, such as Deutsche Börse's EURAU integration, signal a shift toward regulated digital finance [according to recent reports](https://www.coinglass.com/news/757565). However, the report cautions that fragmented regulatory approaches could delay the establishment of a cohesive global framework. For now, the EU's cautious MiCA strategy contrasts with the US's more expansionary GENIUS Act, yet both regions' practical limitations suggest a path toward gradual convergence [as the Riksbank's analysis shows](https://en.bitcoinsistemi.com/stablecoin-report-from-the-swedish-central-bank-europe-and-the-us-are-making-similar-regulations-here-are-the-details/).

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