Hot on the heels of the U.S. GENIUS Act, the Bank of England Governor Andrew Bailey published a very clear and concise framework in the FT entitled “The New Stablecoin Regime”.
As more regulation is clearly coming for stablecoins, all market participants including entrepreneurs need to be aware of the risks and opportunities created by this coming wave.
Let’s therefore first look at the similarities and differences between Bailey’s approach versus the GENIUS Act, to then better understand the associated risks and opportunities.
Firstly, the similarities.
1. Stablecoins need 1:1 backing and peg stability: Goal here is to eliminate the risk of “breaking the peg” and ensure the holders can always redeem at par.
2. Payment instruments, not investments: Stablecoins are a medium of exchange only, unlike crypto assets that could be regulated as investments.
3. Consumer protection and speedy failure resolution: The goal here is to make stablecoin users as protected as bank depositors (or at least close to it).
4. Regulatory oversight and licensing by ways of formal authorization and ongoing supervision: If you issue something that functions like money, you need to be regulated as a financial institution.
As for the differences:
1. BoE is more strict on backing assets (eliminating credit, rate, and FX risk), with the GENIUS Act leaving it at 1:1 backing by high quality reserves.
2. Resolution and Insurance: US emphasizes disclosures and anti-fraud and giving stablecoin holders priority in an insolvency, whereas BoE goes further and proposes a statutory resolution regime plus insurance scheme.
3. The US sees it more as a parallel payments system outside traditional banking yet under financial supervision, whereas BoE sees a closer integration with central-bank infrastructure, possibly even giving systemic issuers access to BoE reserves to ensure full convertibility.
4. The GENIUS Act emphasizes speed, with implementation and detailed rules coming over 18 months. The BoE approach is slower and more prescriptive.
5. BoE is also more silent on stablecoins bearing any sort of interest, whereas the U.S. framework explicitly prevents this.

Overall, the U.S. model is more pragmatic and market led, emphasizing innovation on the margin, whereas the U.K. model is more precautionary and central bank centric, focused more on systemic risk.
The regulation will clearly impose a cost and compliance burden on current market participants, but it will also bring with it increased legitimacy, more widespread adoption, and ideally, greater long term stability.
Another very notable opportunity that this creates for market participants and entrepreneurs is the first step towards fundamentally transforming the future of banking.
Beyond compliance, these regulatory shifts hint at something far deeper — a structural transformation in how money and credit interact.
Historically, money creation and lending went hand in hand under traditional banks. With fractional reserve banking, banks created money out of thin air (you can read my blog on Why Your Money Does Not Exist for more on this), but in return for this literal license to print money, banks were also expected to lend to boost economic growth with lending.
If the creation of money via stablecoins becomes disaggregated from traditional banking, a vacuum will open up. Traditional banks may lose cheap funding (deposits) and to maintain return, they or others, will provide credit through off balance sheet vehicles and private credit funds, i.e. the shadow banking system.
Hence, these new regulations will create a twofold opportunity for fintech entrepreneurs: on the one hand they can create new and innovative companies that use stablecoins as a new kind of money that enables commerce across all corners of the world, while on the other hand they can create new modular and tech driven lending companies that further disaggregates what used to take place under the roof of a traditional bank.
Imagine cross-border B2B platforms settling international trade in stablecoins, or modular credit providers offering 21st century lending solutions using new sources of data such to underwrite in real time.
As entrepreneurs and investors navigate this next chapter, the winners will be those who treat regulation not as constraint but as catalyst — and that’s exactly where we at QED Investors aim to partner and help.

