An in-depth comparative analysis of stablecoin regulations under the European Union’s MiCA and the Central Bank of the UAE’s （CBUAE） regulatory frameworks. The article explores their impact on the digital asset space and the broader financial ecosystem.
Points
- MiCA establishes comprehensive crypto regulations in the EU.
- CBUAE focuses on AED-backed and foreign currency stablecoins.
- Regulatory requirements and use cases for stablecoins differ significantly.
- The influence of FATF on regulatory approaches and the implications for the digital asset industry.
The European Union’s comprehensive crypto law, MiCA （Markets in Crypto-Assets）, officially enforced in May 2023, and the Central Bank of the UAE’s （CBUAE） regulatory framework represent significant steps towards establishing stablecoin regulations. These regulations aim to harmonize rules for crypto assets across their respective regions, ensuring transparency, security, and stability in the digital asset space.
Types of Stablecoins and Issuers
MiCA:
MiCA distinguishes between asset-referenced tokens （ARTs） and e-money tokens （EMTs）. ARTs maintain their value by referencing assets like gold or a basket of currencies, while EMTs are pegged to a single official currency, including non-EU currencies. Issuers must obtain a MiCA license to offer or trade ARTs or EMTs within the EU.
CBUAE:
The CBUAE focuses on AED-backed stablecoins but also allows for the issuance of foreign currency stablecoins on a case-by-case basis. Entities wishing to issue Dirham stablecoins must obtain a license from the Central Bank.
Regulatory Requirements
MiCA:
MiCA mandates issuers to submit a detailed whitepaper to regulators, outlining information about the issuer, the token, reserve asset management, and associated risks. Both EMT and ART issuers must adhere to prudential rules, governance requirements, and restrictions against granting interest on tokens. Issuers must hold at least 30% of funds received as deposits in credit institutions.
CBUAE:
The CBUAE emphasizes risk-based licensing, stringent oversight, and clear guidelines for managing reserves and redemption activities. Banks are permitted to invest up to 50% of their reserves in government securities. Custody and conversion of Dirham stablecoins require Central Bank licenses.
Use of Stablecoins
MiCA:
ARTs cannot be used as a means of payment, limiting their functionality compared to traditional currency or e-money. EMTs, however, can be used as a means of payment for goods and services, providing greater utility and aligning with EU regulations.
CBUAE:
AED-backed stablecoins can be used for payments, tokenization, and cross-border transactions. However, foreign stablecoins cannot be directly used for payments within the UAE, preserving financial sovereignty.
解説
- Regulatory Approach: MiCA’s detailed requirements and distinctions between ARTs and EMTs provide a structured regulatory environment, while CBUAE’s focus on AED-backed stablecoins creates a unique ecosystem for financial transactions.
- Compliance and Security: Both regulatory frameworks prioritize risk management, investor protection, and compliance with international standards, ensuring the stability and security of the stablecoin market.
- Market Impact: The regulations under MiCA and CBUAE have the potential to significantly influence the global digital asset space, encouraging innovation while ensuring regulatory oversight and consumer protection.
- FATF Influence: The differing approaches highlight the geopolitical contexts and compliance with FATF guidelines, shaping how stablecoins are integrated into the broader financial system.