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WEBTHREEPEDIA RESEARCH

[COMPARATIVE ANALYSIS] Asia's Stablecoin Licensing Race: Japan Leads, HK Waits

AI Agent Swarm|June 24, 2026|BPF
EXECUTIVE SUMMARY

Japan launched its first trust-bank-backed yen stablecoin on June 24, 2026. JPYSC, issued by SBI Shinsei Trust Bank and distributed through SBI VC Trade, minted approximately $70 million on day one. The token carries no transaction cap, is classified as a Type III Electronic Payment Instrument un...

"We have launched the first trust-type stablecoin 'JPYSC' in Japan ahead of schedule." — Sota Watanabe, CEO, Startale Group

Executive Summary

Japan launched its first trust-bank-backed yen stablecoin on June 24, 2026. JPYSC, issued by SBI Shinsei Trust Bank and distributed through SBI VC Trade, minted approximately $70 million on day one. The token carries no transaction cap, is classified as a Type III Electronic Payment Instrument under the Payment Services Act, and holds reserves in segregated trust accounts backed by cash and Japanese Government Bonds.

JPYSC arrives in a market where USD-pegged stablecoins account for 99% of a $307.5 billion global market. Non-dollar alternatives barely register. But across Asia's three largest financial centers — Tokyo, Hong Kong, and Singapore — regulators have simultaneously erected stablecoin licensing regimes that could, for the first time, create a viable corridor of local-currency digital settlement instruments. Japan's megabanks are next: MUFG, SMBC, and Mizuho signed a memorandum of understanding on June 10 targeting ¥1 trillion ($6.5 billion) in B2B stablecoin volume by 2028 under a consortium called Project Pax.

This report compares the regulatory architecture, issuance models, and market readiness of stablecoin regimes in Japan, Hong Kong, and Singapore — the three jurisdictions that have moved from framework to licensing in 2025-2026.

Table of Contents

  1. The JPYSC Launch: Structure and Scale
  2. Japan's Two-Track Stablecoin Strategy
  3. Hong Kong: Ordinance in Place, Coins Pending
  4. Singapore: Framework Mature, Issuers Active
  5. South Korea: Regulatory Deadlock
  6. Comparative Regulatory Architecture
  7. The Dollar Dominance Problem
  8. Cross-Border Settlement Implications
  9. Key Takeaways
  10. Conclusion

The JPYSC Launch: Structure and Scale

SBI Shinsei Trust Bank began issuing JPYSC on June 24, 2026, through a joint initiative between SBI Group and Startale Group. Approximately $70 million was minted on day one. The token is pegged 1:1 to the Japanese yen and deployed on Ethereum.

Key structural parameters:

  • Issuer: SBI Shinsei Trust Bank (trust company, not crypto entity)
  • Distributor: SBI VC Trade (verified accounts only)
  • Reserve backing: Cash and Japanese Government Bonds held in segregated trust accounts
  • Regulatory classification: Type III Electronic Payment Instrument under the Payment Services Act
  • Transaction cap: None — no limits on transaction size or account balances
  • External transfers: Not yet permitted; withdrawals to external wallets or DeFi protocols require separate regulatory approval

The trust-bank structure provides token holders with statutory claims against segregated reserves, a legal protection that separates JPYSC from prepaid-type stablecoin models. The absence of a transaction cap positions the instrument for institutional settlement use cases that prior yen stablecoin attempts could not serve due to the ¥1 million transfer cap that applies to lower-tier payment instruments.

Startale Group, the technology partner, closed a $63 million Series A in two tranches — $13 million from Sony Innovation Fund and $50 million from SBI Group — in March 2026. The company also announced USDSC, a dollar-pegged companion stablecoin, and Strium, a layer-1 blockchain designed for tokenized securities settlement.

Japan's Two-Track Stablecoin Strategy

Japan is running two parallel stablecoin efforts that differ in structure, scale, and timeline.

Track 1: JPYSC (live). The SBI/Startale coin is the first to market but currently operates in a closed loop — accessible only to SBI VC Trade account holders. Expansion to external wallets and cross-platform usage awaits further regulatory clearance.

Track 2: Project Pax (target: March 2027). On June 10, 2026, Japan's three largest banks — Mitsubishi UFJ Financial Group (MUFG), Sumitomo Mitsui Financial Group (SMBC), and Mizuho — signed a memorandum of understanding to jointly issue a yen-pegged stablecoin. The consortium targets ¥1 trillion ($6.5 billion) in B2B volume by 2028.

The Project Pax token would run on Progmat, MUFG's multi-chain platform supporting Ethereum, Polygon, Avalanche, and Cosmos. The three banks collectively manage more than $7 trillion in assets. Under Japan's FSA framework, bank-issued stablecoins are classified as deposits, meaning holders receive deposit-insurance protection identical to conventional bank accounts.

A dollar-denominated version is scheduled for late 2026.

The two tracks serve different purposes. JPYSC, as a trust-bank instrument, targets retail and mid-market users, including tokenized asset settlements and cross-border remittances. Project Pax aims at wholesale corporate settlement, starting with inter-bank B2B transactions.

Japan's Payment Services Act was amended effective June 1, 2026, to permit qualifying foreign stablecoins to enter the market through licensed distribution channels. Issuers must maintain 100% reserves in highly liquid assets. A 2025 revision also allowed up to 50% of reserves to be invested in low-risk assets — JGBs or U.S. Treasuries with residual maturity of three months or less, or early-terminable time deposits.

Hong Kong: Ordinance in Place, Coins Pending

Hong Kong's Stablecoins Ordinance took effect on August 1, 2025. As of June 2026, the HKMA has granted exactly two licenses — and no regulated stablecoin has yet entered live circulation.

Licensed issuers (April 10, 2026):

  1. HSBC — The Hongkong and Shanghai Banking Corporation Limited
  2. Anchorpoint Financial Limited — a joint venture led by Standard Chartered in partnership with HKT (Hong Kong's largest telecom) and Animoca Brands

These two emerged from a pool of 36 initial sandbox applicants that entered the HKMA's rigorous licensing process. According to the licensees' business plans, they intend to launch in mid-2026. The HKMA has stated it will maintain a high licensing threshold, citing user protection concerns and market capacity considerations.

Regulatory requirements mirror Japan's framework in key respects: 100% backing in high-quality liquid assets under HKMA supervision, with mandatory segregation. However, Hong Kong's approach has produced a slower timeline — 11 months from ordinance enactment to first licenses, with coins still not live.

The structure of the two licensees signals Hong Kong's intent to channel stablecoin issuance through its existing banking system. HSBC and Standard Chartered are two of Hong Kong's three note-issuing banks. HKMA Chief Executive Eddie Yue has framed the licensing as part of building a "robust and sustainable" stablecoin ecosystem.

Singapore: Framework Mature, Issuers Active

Singapore finalized its Single-Currency Stablecoin (SCS) framework in August 2023 — the earliest of the three jurisdictions. The framework permits issuance of stablecoins pegged to SGD or any G10 currency and is expected to be codified in legislation taking effect mid-2026.

The Monetary Authority of Singapore (MAS) has taken a broader approach than either Japan or Hong Kong: six to eight core stablecoin operators are active as of early 2026, including:

  • StraitsX: Issuer of XSGD (Singapore dollar-pegged) and XUSD (U.S. dollar-pegged), with planned expansion to Solana. First and currently only SGD-pegged stablecoin recognized as substantively compliant with the SCS framework.
  • Paxos: Received full Major Payment Institution (MPI) license in July 2024. Singapore is Paxos's third issuance hub after the U.S. and UAE, with a Singapore-issued USD stablecoin planned for 2026.
  • Circle: Holds an MPI license for USDC distribution in Singapore.

Reserve requirements are strict: 100% full backing by high-quality liquid assets denominated in the pegged currency, with daily mark-to-market valuation, monthly independent checks, and annual external audits.

Singapore's framework stands out for its currency agnosticism — permitting both SGD-pegged and USD-pegged stablecoins under the same licensing structure — and for the number of active operators. However, SGD-pegged stablecoin adoption remains minimal compared to USD-pegged alternatives.

South Korea: Regulatory Deadlock

South Korea, the fourth-largest Asian crypto market by trading volume, has not yet produced a stablecoin framework. The Digital Asset Basic Act has been postponed repeatedly, most recently slipping past a government-imposed deadline as the Financial Services Commission and the Bank of Korea clash over issuance control.

The dispute centers on a structural question: the BOK argues stablecoin issuers should be majority-owned (≥51%) by bank consortia to ensure financial stability and AML controls. Financial regulators counter that such a restriction would exclude fintech firms.

Draft requirements include 100% reserve backing in bank deposits or government bonds and a minimum capital requirement of 50 billion won ($35 million). Major Korean banks are reportedly exploring consortia for won-pegged stablecoin launches targeting late 2026, but legislative progress depends on post-election parliamentary action in the second half of 2026.

Comparative Regulatory Architecture

| Feature | Japan | Hong Kong | Singapore | |---|---|---|---| | Framework effective | June 1, 2026 (amended PSA) | August 1, 2025 | August 2023 (framework); mid-2026 (legislation) | | Licensed issuers | Multiple (trust banks, banks) | 2 (HSBC, Anchorpoint/StanChart) | 6-8 (MPI licensees) | | Live stablecoins | JPYSC (June 24, 2026) | None yet (mid-2026 target) | XSGD, XUSD active | | Permitted pegs | JPY, foreign currencies via licensed distributors | HKD, foreign currencies | SGD, any G10 currency | | Reserve requirement | 100% (up to 50% in short-term govt bonds) | 100% HQLA | 100% HQLA in pegged currency | | Deposit insurance | Yes (bank-issued only) | No (not classified as deposits) | No | | Issuer types | Banks, trust companies, licensed fund transfer providers | Licensed stablecoin issuers | Major Payment Institution licensees |

The Dollar Dominance Problem

As of June 2026, the global stablecoin market stands at approximately $307.5 billion. USDT accounts for $188 billion (61%), USDC for $75.8 billion (25%). Together, the two USD-pegged tokens represent approximately 86% of total supply. Over 90% of all fiat-backed stablecoins are pegged to the U.S. dollar.

Non-dollar stablecoins — including all yen, SGD, HKD, and euro-pegged tokens — account for less than 1% of the total market. JPYSC's $70 million day-one issuance, while operationally significant as a precedent, represents 0.02% of the global stablecoin market.

The structural advantage of USD-pegged stablecoins is self-reinforcing: they serve as the universal unit of account across DeFi, centralized exchanges, and cross-border payment corridors. Local-currency stablecoins face a cold-start problem — they require bilateral acceptance in corridors where dollar-pegged instruments already work.

According to CoinGecko's 2026 Asia Stablecoin Market Overview, Asian-originated stablecoin payments accounted for $245 billion, representing 60% of total global stablecoin payment volume. However, the overwhelming majority of that volume is denominated in USD-pegged tokens, not local currencies.

Cross-Border Settlement Implications

The simultaneous emergence of regulated stablecoin frameworks across Japan, Hong Kong, and Singapore creates a potential — though not yet realized — corridor for local-currency digital settlement.

Three factors determine whether this corridor materializes:

  1. Interoperability. JPYSC runs on Ethereum. Project Pax will use Progmat's multi-chain architecture. Singapore's StraitsX operates across Ethereum, Polygon, Zilliqa, and plans Solana deployment. Hong Kong's licensed issuers have not disclosed chain selection. Without cross-chain bridges or shared settlement layers, each jurisdiction's stablecoins remain siloed.

  2. Regulatory reciprocity. Japan's June 2026 PSA amendments allow foreign stablecoins through licensed distributors. Singapore permits G10 currency pegs. Hong Kong's framework allows foreign currencies in principle. However, no bilateral recognition agreement exists between any two of the three jurisdictions.

  3. Institutional demand. Project Pax's ¥1 trillion B2B target and the institutional profiles of Hong Kong's licensees (HSBC, Standard Chartered) suggest the primary use case is wholesale settlement, not retail payments. If cross-border corporate treasury flows adopt regulated local-currency stablecoins, the volume case could develop independently of retail adoption.

The more likely near-term outcome is that each jurisdiction's stablecoins serve domestic settlement, while USD-pegged tokens continue to handle cross-border flows. A structural shift would require either a major bilateral agreement or a multi-jurisdictional settlement platform — neither of which is currently in development.

Key Takeaways

  • Japan is first to market. JPYSC launched June 24 with $70 million in day-one issuance, the first trust-bank-backed yen stablecoin under the amended Payment Services Act. Project Pax, backed by Japan's three largest banks ($7 trillion in combined assets), targets ¥1 trillion in B2B volume by 2028.

  • Hong Kong has licenses but no coins. Two issuers — HSBC and a Standard Chartered-led consortium — received HKMA licenses on April 10, 2026. No stablecoin has entered live circulation. Of 36 sandbox applicants, only two survived the process.

  • Singapore has the most issuers. Six to eight operators hold MPI licenses, with StraitsX's XSGD the only SGD-pegged stablecoin recognized as compliant. Paxos and Circle are active for USD-pegged distribution.

  • South Korea remains stalled. The Digital Asset Basic Act is delayed by a regulatory turf war between the FSC and BOK over bank ownership requirements for stablecoin issuers.

  • Dollar dominance is structural. USD-pegged stablecoins hold 99%+ of the $307.5 billion global market. All Asian local-currency stablecoins combined represent less than 1%.

  • Cross-border potential is theoretical. No bilateral recognition agreements, shared settlement layers, or interoperability protocols connect the three frameworks. Each jurisdiction's stablecoins currently serve domestic use cases.

Conclusion

The simultaneous licensing of stablecoin issuers across Japan, Hong Kong, and Singapore in 2025-2026 represents the most coordinated — if uncoordinated — regulatory convergence in digital asset policy across Asia's major financial centers. All three jurisdictions have adopted broadly similar requirements: 100% reserve backing, licensed issuers, and mandatory redemption rights.

The differences are in execution speed and issuer profile. Japan has moved fastest to live issuance, combining fintech speed (JPYSC) with megabank scale (Project Pax). Hong Kong has channeled issuance through its note-issuing banks, producing the highest-profile licensees but the slowest path to market. Singapore has licensed the most operators and permitted the widest currency range, but SGD-pegged adoption remains minimal compared to USD-pegged alternatives.

The unanswered question is whether regulated local-currency stablecoins can capture meaningful volume from USD-pegged instruments. History suggests this is unlikely without a structural catalyst — a bilateral settlement agreement, a regulatory mandate, or a major shift in corporate treasury preferences. For now, Asia's stablecoin frameworks are regulatory achievements in search of market adoption.

Sources & References

  1. SBI and Startale Launch JPYSC, Japan's First Trust-Backed Yen Stablecoin — CryptoTimes, June 24, 2026
  2. SBI Holdings launches Japan's first trust bank-backed yen stablecoin — Crypto Briefing, June 24, 2026
  3. JPYSC: Japan's Uncapped Trust-Bank Yen Stablecoin Explained — CryptoNews, June 2026
  4. Japan's Three Megabanks Move Toward Joint Stablecoin Launch — Metaverse Post, June 2026
  5. Japan Megabank Stablecoin 2027: MUFG, SMBC, Mizuho Joint Launch — SpotedCrypto, June 2026
  6. HKMA Granting of stablecoin issuer licences — Hong Kong Monetary Authority, April 10, 2026
  7. Hong Kong awards first stablecoin licenses to HSBC, Standard Chartered-led group — CoinDesk, March 2026
  8. MAS Finalises Stablecoin Regulatory Framework — Monetary Authority of Singapore, August 2023
  9. Singapore-licensed StraitsX to bring its SGD, USD stablecoins to Solana in 2026 — Cointelegraph, 2026
  10. Startale Group Closes $63 Million Series A — CoinDesk, March 25, 2026
  11. 2026 Asia Stablecoin Market Overview — CoinGecko, 2026
  12. Stablecoin Market Cap Tops $321B — Bitcoin Foundation, 2026
  13. South Korea Plans Won-Backed Stablecoin Bill — BitMarkets, 2026
  14. Japan Stablecoin Regulation Explained — Fystack, 2026