
GENIUS Act
What it does
Toku's take

CLARITY Act
What it does
Toku's take

MiCA
What it does
Toku's take
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BCB Resolutions 519–521
What it does
Toku's take

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The regulatory landscape for stablecoin payroll is moving fast. We monitor the legislation that matters for companies paying employees and contractors across borders and tell you what it means for your payroll program.
Updated June 1, 2026 · 5 jurisdictions tracked · Updated quarterly
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A stablecoin is a digital token pegged to a reference asset, usually the US dollar, and backed one-to-one by reserves. It is not legal tender, because it is not issued by a central bank or treasury. Under the US GENIUS Act, payment stablecoins are regulated as digital money, not as securities or bank deposits.
Yes, and increasingly so. The US GENIUS Act and the EU's MiCA both set licensing and full-reserve rules for stablecoin issuers, and Hong Kong, the UK, and others have their own regimes. The common thread is 1:1 reserves, licensed issuance, redemption at par, and AML/KYC. The detail varies by country, which is what this tracker follows.
The GENIUS Act is the US federal law for payment stablecoins, signed in July 2025. It limits issuance to permitted issuers licensed federally through the OCC or under state authority, requires 1:1 backing in cash and short-dated Treasuries, and classifies payment stablecoins as digital money rather than securities. Implementing rules are rolling out through 2026.
MiCA is the EU's Markets in Crypto-Assets regulation. Fiat-backed stablecoin issuers must be authorized as e-money institutions to serve EU users, hold liquid 1:1 reserves, and allow redemption at par. Any issuer offering a stablecoin into the EU market must comply, with authorization deadlines for existing issuers in 2026.
Yes. In the US, issuers need a federal license through the OCC or authorization under a qualifying state regime, with banks covered by their existing charters. In the EU, issuers need e-money-institution authorization under MiCA. Issuing a payment stablecoin into these markets without a license is restricted.
It depends on the worker type and jurisdiction. In most US states, W-2 employees must be paid in US dollars, so stablecoin is usually delivered as a portion of net pay rather than the gross wage. Independent contractors can generally be paid in stablecoin by agreement. Confirm local wage law first, and consult your legal counsel.
As ordinary income. The IRS values stablecoin paid for work at its fair-market value on the payment date, reported on a W-2 for employees, with income-tax and FICA withholding, or on a 1099-NEC for contractors paid over $600. Paying in stablecoin changes how funds settle, not the withholding or reporting obligations.
Materially. The US GENIUS Act, EU MiCA, and Hong Kong's Stablecoins Ordinance each run separate licensing and reserve regimes, and they are not interchangeable: a reserve structure that satisfies one may fail another. This tracker monitors those differences across jurisdictions so you can see where each market stands at a glance.
Quarterly. Toku reviews stablecoin and employment legislation across 100+ countries and refreshes the tracker every quarter, so the status shown reflects the most recent quarterly review rather than a fixed snapshot.
Toku provides compliance infrastructure and is not a law firm. This content is for informational purposes only and does not constitute legal or tax advice.