Japan Pioneered Stablecoin Rules, But the U.S. Is Pulling Ahead
Japan may have been the first to implement a comprehensive stablecoin regulatory framework back in 2023, but the U.S. is quickly moving past it with a more market-driven approach. The contrast highlights not just different timelines, but fundamentally different philosophies about how innovation and stability should be balanced.
While Japan built its rulebook around systemic stability, the U.S. has gone all-in on opening the gates to wider participation — and that difference could shape the global stablecoin market for years to come.
Japan’s Early Lead in Regulation
In 2023, Japan amended its Payment Services Act, setting clear and strict boundaries for stablecoin issuers. Under these rules, only licensed banks, trust banks, and registered money transfer agents were permitted to issue yen-backed stablecoins.
On paper, this gave Japan a regulatory head start. It was the first country to set a complete framework that emphasized investor protection and systemic safety. But the outcome has been muted. Despite the clarity, there isn’t yet a thriving yen-stablecoin economy. Adoption remains slow, with issuers technically licensed but struggling to create meaningful utility.
The U.S. GENIUS Act Shifts Momentum
Fast forward to 2025, and the U.S. has taken a different tack with the GENIUS Act, which is widely celebrated as a catalyst for stablecoin adoption. Unlike Japan’s bank-only issuance model, the U.S. approach allows both banks and federally licensed non-bank firms to issue stablecoins — as long as they meet reserve and compliance standards.
This wider aperture signals a more market-opening philosophy, one that prioritizes adoption and innovation speed. According to Takashi Tezuka, Startale Group’s Japan country manager, this is why the U.S. seems to be pulling ahead:
“Japan prizes systemic stability above innovation speed, while the U.S. is signaling a bigger market-opening play.”
The First Yen Stablecoins Are Coming
Despite lagging adoption, Japan is finally nearing a breakthrough. Later this year, fintech company JPYC is set to launch the country’s first yen-backed stablecoin. It will be fully collateralized with bank deposits and Japanese government bonds, ensuring a one-to-one peg with the yen.
Another major player, Tokyo-based Monex Group, is also considering entry. With subsidiaries like Tradestation and Coincheck, Monex has the scale and credibility to accelerate yen-stablecoin usage across corporate settlements and global remittances.
If these initiatives succeed, Japan will finally make its long-awaited debut into the $270 billion global stablecoin market — a market still overwhelmingly dominated by U.S. dollar stablecoins like Tether’s USDT and Circle’s USDC.
Japan’s Infrastructure-First Strategy
Tezuka believes Japan’s measured approach is part of a bigger play. Instead of rushing adoption, Japan is laying the groundwork for programmable, enterprise-grade capital markets.
Startale Group, his firm, has partnered with financial giant SBI Holdings, which is simultaneously collaborating with USDC issuer Circle and blockchain firm Ripple. Together, they are building infrastructure for tokenized stocks, real-world assets, and expanded corporate use of stablecoins.
This infrastructure-first strategy could eventually pay off. For now, it makes Japan look slow. But as capital markets move toward tokenization, programmable treasuries, and automated financial operations, Japan’s approach may give it a structural advantage.
Final Thought
Japan may look like it’s falling behind the U.S. in the stablecoin race, but its slow and cautious path could still prove wise in the long run. While the U.S. is chasing rapid adoption, Japan is building a foundation for sustainable, enterprise-level growth. The first wave of yen-backed stablecoins — if successful — could mark the beginning of Japan’s resurgence in the global stablecoin economy.
