Global Crypto Policy Shifts: Key Takeaways from Q2 2026
The second quarter of 2026 was the period when stablecoin accounting moved from a niche compliance question to a mainstream financial infrastructure concern. Across the UK, EU, US, and a broad sweep of Asian markets, regulators published final rules, closed transitional windows, and began enforcement actions that have real consequences for accounting firms, CFOs, and their auditors today. Here is what happened, jurisdiction by jurisdiction, and what it demands of finance teams now.
UK: Final FCA Rules and a New Tax Framework
The Financial Conduct Authority published its final rules for regulating crypto activity in the UK during Q2, covering trading platforms, issuers, custodians, and intermediaries. The authorisation gateway opens on 30 September 2026, with the full regime in force by 25 October 2027. Industry reaction has been broadly positive, particularly around the stablecoin provisions.
Where the perimeter still needs clarity
Two questions remain unresolved. First, exactly where the FCA draws its regulatory perimeter for borderline products and business models. Second, how certain activities are categorised within the new framework. Both questions matter for firms deciding right now whether to seek authorisation, restructure their service offerings, or apply for a transitional permission. Getting that decision wrong carries material licensing risk, so finance teams should be working with legal counsel to map their activities against the FCA's published final rules before September.
HMRC's crypto tax legislation
On the tax side, HM Revenue and Customs published legislation setting out the tax treatment of liquidity pool participation, staking, and related crypto activities. The direction of travel is significant: HMRC is explicitly moving away from treating crypto as an exceptional asset class and toward treating it as any other form of value. For UK-based clients or entities with UK tax obligations, this means the ad hoc interpretive approach of recent years is closing. Firms need documented positions on staking income recognition, liquidity pool gain calculations, and cost basis methodology, because HMRC's framework now provides a legislative anchor against which those positions will be tested. For deeper context on how stablecoin accounting interacts with UK and European rule changes, see our analysis of MiCA's impact on stablecoin accounting teams.
Sanctions and AI on the UK agenda
The UK also registered two enforcement-adjacent developments. The sanctioning of HTX, the fifth-largest exchange globally, will pressure-test existing UK guidance on dealing with sanctioned entities and their counterparties. Giles Thompson, head of the Office of Financial Sanctions Implementation, signalled that further crypto designations are likely. Thompson also became the new president of the Financial Action Task Force this quarter, with stated priorities around a risk-based approach, countering fraud, and public-private partnerships. On artificial intelligence, the FCA published commentary through the Sheldon Mills-led review on AI in retail financial services, with both the FCA and the European Central Bank flagging AI-related cyber threats. The current regulatory posture on AI is described as pragmatic: guardrails rather than prescriptive rules.
EU: MiCA Closes Its Transitional Period
1 July 2026 marked the end of the Markets in Crypto Assets transitional period, completing the multi-year process from drafting to full application. Any crypto-asset service provider that was relying on national transitional permissions in EU member states needed to be authorised or out of scope by that date.
MiCA 2 consultation opens
Almost simultaneously, the European Commission opened its MiCA 2 consultation, which reopens a fundamental question: is MiCA still fit for purpose as a standalone crypto regulation, or should crypto eventually be folded into general EU financial services regulation, moving closer to the UK's approach? This is not an academic question. If the EU shifts to a general financial services model, the classification, disclosure, and prudential requirements that currently apply to crypto-asset issuers and service providers under MiCA could be replaced by a different set of obligations. Accounting teams should monitor MiCA 2 closely because it will affect how stablecoin assets are classified on balance sheets across European entities.
AMLA, the digital euro, and what they mean for books
The EU's Anti-Money Laundering Authority continued ramping up its work this quarter, with a series of consultations touching digital assets. The European Parliament also approved the digital euro. From an accounting perspective, the digital euro approval raises presentation questions that haven't yet been answered by IASB or national standard-setters: would a digital euro holding be treated as cash, a cash equivalent, or a separate financial instrument? Finance teams operating in the EU should flag this to their auditors now rather than waiting for a standard to land. For practical guidance on how stablecoin accounting standards are evolving in this direction, our coverage of FASB's proposed stablecoin cash equivalents guidance provides a useful US GAAP parallel.
APAC: Movers, Shakers, and Sleeping Giants
The APAC picture is best understood through three categories: jurisdictions that have already acted, those actively building frameworks, and large markets that haven't moved decisively yet.
Movers: Singapore, Hong Kong, Japan, Taiwan
Singapore's Digital Token Service Provider regime remains in force, though a standalone stablecoin framework first published over two years ago has still not taken effect. Signs suggest it could advance in coming months, and Singapore is pursuing real-economy stablecoin use cases through Project Bloom. Hong Kong has issued two licences under its Stablecoins Ordinance since that law took effect in August 2025, with a clear preference for a bank-led model. Japan has continued refining its Payment Services Act framework, creating new categories for stablecoin issuers. It has now approved three stablecoins for issuance: USDC first, then JPYC, and most recently RLUSD. Japan's finance minister also signalled plans to move crypto taxation away from income-style rates toward something closer to capital gains treatment, explicitly linking high tax rates to constrained market dynamism. Taiwan passed a Virtual Asset Services Act during the quarter, with attention now turning to implementing regulations.
Shakers: South Korea, Indonesia, Thailand, the Philippines
South Korea's Digital Asset Basics Act remains pending in the National Assembly. Local elections in June slowed momentum, and the market is waiting to see the government's own version of the bill. Indonesia moved crypto oversight to twin regulators, the Financial Services Authority and Bank Indonesia, signalling that a formal digital asset framework is coming. Thailand unilaterally declared US dollar stablecoins, including USDC, valid trading pairs, with the Bank of Thailand signalling further policy development. The Philippines central bank has put crypto asset service provider rules in place, with large remittance corridors positioning stablecoins as a potential mechanism to meaningfully lower the cost of cross-border transfers.
Sleeping giants: India and China
India and China haven't moved decisively, but both are experimenting. India's central bank approved ARC, a privately issued instrument functioning as a hybrid digital asset, even as enforcement remains India's primary posture toward crypto broadly. China's e-CNY reached roughly RMB 7.3 trillion in transaction volume in 2024, with the People's Bank of China shifting focus from retail payment use cases, which saw limited traction, toward institutional applications. Neither market has created a path for international stablecoin issuers. If either does, the accounting and AML implications for global firms would be, in the words used at the roundtable, tectonic.
Accounting implications across APAC
For accounting firms and CFOs with APAC exposure, the APAC picture creates an uneven compliance landscape. A firm operating across Singapore, Japan, and the Philippines faces three distinct licensing regimes, two of which are still being finalised, and tax treatment that varies materially by jurisdiction. Stablecoin accounting entries that work under one regime may need adjustment under another. Firms should maintain jurisdiction-specific documentation for each entity that holds or transacts in stablecoins, and those workpapers should be updated as Singapore's stablecoin framework and South Korea's Digital Asset Basics Act progress.
US: GENIUS Act Turns One, CLARITY Act Moves to the Senate Floor
The GENIUS Act marked its one-year anniversary this quarter, and the conversation has shifted decisively from whether legislation would pass to how implementation works in practice. The Office of the Comptroller of the Currency issued a proposal addressing bank-side compliance for stablecoin issuers. Separately, the Financial Crimes Enforcement Network and the Office of Foreign Assets Control published guidance on what strong AML and sanctions compliance should look like for stablecoin activity specifically.
CLARITY Act: out of committee, heading to the floor
The Senate Banking Committee voted the CLARITY Act, the companion market structure bill to the GENIUS Act, out of committee. It now heads to a floor vote, where it will need to be reconciled with the House-passed version. Outstanding issues include ethics provisions covering officials' crypto holdings, though the bill already includes 20 provisions supporting law enforcement. With midterm elections in November compressing the legislative calendar, there is real uncertainty about whether CLARITY clears the Senate in time. Some form of market structure legislation is broadly expected regardless, covering the security-versus-commodity boundary and how oversight splits between the SEC and the CFTC.
Agency action continues despite congressional gridlock
Even with Congress slow-moving, agencies kept producing output. The SEC published a token taxonomy this quarter as part of approximately 20 separate actions aimed at providing regulatory clarity. Closer coordination between the SEC and CFTC was noted as a meaningful development. On sanctions, OFAC is no longer alone in publishing crypto address designations: Israel and Japan have taken similar steps, even if less systematically. For firms onboarding digital asset counterparties, the expanding universe of jurisdictions publishing crypto-linked sanctions designations raises the due diligence bar. Our framework for VASP due diligence and onboarding covers how to build a process that holds up to multi-jurisdictional scrutiny.
What This Means for Stablecoin Accounting Teams
A consistent theme across every jurisdiction discussed was the shift from treating stablecoins as a novel or experimental product to treating them as financial infrastructure. That shift has direct consequences for how stablecoin accounting is handled.
Classification and presentation
Stablecoins that meet the conditions being set out in frameworks like the GENIUS Act implementation rules, MiCA's e-money token regime, or Hong Kong's Stablecoins Ordinance are increasingly being positioned as cash-equivalent instruments by the regulatory community, even where the accounting standards haven't caught up. Firms should document their classification rationale at the balance sheet date and revisit it each period as the standards evolve. FASB's proposed ASU on stablecoin cash equivalents is the most advanced accounting standard-setter position currently in public comment; IASB has not yet issued equivalent guidance for IFRS reporters.
AML and transaction monitoring
The OFAC and FinCEN guidance published in the US this quarter, alongside AMLA's consultations in the EU and Singapore's enforcement actions against offshore-only DTSP registrants, all point to rising expectations around transaction monitoring for stablecoin flows. Firms providing accounting services to stablecoin issuers, holders, or intermediaries should ensure that AML controls are addressed in engagement scope and that transaction data is being retained in a form that supports suspicious activity reporting.
Tax treatment in flux
Japan signalling a move toward capital gains treatment, the UK legislating on staking and liquidity pools, and Thailand's unilateral stablecoin trading pair recognition all create a patchwork of tax treatments across the jurisdictions covered. For multinational entities, transfer pricing documentation and permanent establishment analysis should explicitly address stablecoin treasury operations and any yield generated from stablecoin holdings.
Frequently Asked Questions
When does the UK FCA's new crypto regime take full effect?
The FCA's authorisation gateway opens on 30 September 2026. The full regime, covering trading platforms, issuers, custodians, and intermediaries, comes into force by 25 October 2027. Firms that need to be authorised should begin their applications as soon as the gateway opens, since processing time is not guaranteed to fit within the window.
What does the end of MiCA's transitional period mean for EU entities?
As of 1 July 2026, national transitional permissions for crypto-asset service providers in EU member states have closed. Any firm that was operating under a transitional arrangement needed to be fully authorised under MiCA or have restructured out of scope by that date. Operating without authorisation after 1 July exposes firms to regulatory action from national competent authorities.
How should accounting teams treat stablecoin holdings under current standards?
Under IFRS, there is no dedicated standard for stablecoins. Most IFRS reporters classify them as intangible assets under IAS 38, though some argue for financial instrument treatment. Under US GAAP, FASB's proposed ASU would allow qualifying stablecoins to be treated as cash equivalents; that proposal is not yet final. Firms should document their chosen policy, apply it consistently, and disclose the accounting policy and any significant judgements in the notes to the financial statements.
Does Japan's approval of USDC, JPYC, and RLUSD affect accounting for firms with Japanese entities?
Yes. Approved stablecoin issuances under Japan's amended Payment Services Act framework carry specific reserve and disclosure requirements for issuers. For holders, the approved status affects how the instruments are classified for Japanese regulatory capital and reporting purposes. Firms with Japanese subsidiaries holding any of these three stablecoins should confirm their local accounting treatment with Japanese advisers, particularly if those holdings are material.
What practical steps should a CFO take now given the pace of global stablecoin regulation?
Three immediate actions are worth prioritising. First, map every jurisdiction in which your entity holds, issues, or transacts in stablecoins against the regulatory status in that jurisdiction as of Q2 2026, noting which frameworks are final and which are still pending. Second, review your stablecoin accounting policy against FASB's proposed cash equivalents guidance and any applicable IFRS interpretations, and document the rationale for your chosen treatment. Third, ensure your AML transaction monitoring covers stablecoin flows and that your OFAC and equivalent sanctions screening includes crypto address checks, given the expanding range of jurisdictions now publishing crypto-linked designations.
Source: TRM Labs