Japan wrote the first stablecoin rulebook — so why is the US pulling ahead?

While the US GENIUS Act is being celebrated as a market catalyst for stablecoin adoption, Japan’s earlier reforms show the flip side: Clarity doesn’t automatically translate into immediate real-world utility. 

Japan had the world’s first comprehensive stablecoin regime in 2023, but adoption has been muted. Licensed issuers exist on paper, yet there’s no thriving yen-stablecoin economy.

In an interview with Cointelegraph, Takashi Tezuka, country manager at Web3 infrastructure developer Startale Group, said the adoption gap between the US and Japan reflects a philosophical difference in regulatory design.

“The GENIUS Act was greeted with a mix of relief and curiosity,” Tezuka said, “because the US has finally caught up with what Japan did two years earlier — putting a comprehensive legal framework around stablecoins.” 

Under to the Payment Services Act, only licensed banks, trust banks and registered money transfer agents are permitted to issue stablecoins. 

The US approach under the , by contrast, opens the door more widely: Not only banks, but also federally licensed non-bank companies can pursue stablecoin issuance, provided they meet reserve and compliance standards.

This underscores a philosophical divide. “Japan prizes systemic stability above innovation speed, while the US is signaling a bigger market-opening play,” Tezuka noted.

Still, the gap may not last long. Japan’s infrastructure-first strategy “mirrors broader industry signals — global players are building infrastructure to support programmable, enterprise-grade capital markets, and Japan’s measured, infrastructure-first mindset positions the country to compete as the regulatory landscape matures.”

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First yen-backed stablecoin set to launch this year

After laying the regulatory groundwork for the past two years, Japan is set to approve its first yen-den stablecoin this fall, opening the door to blockchain-based remittances and payments of its national currency.  

The first stablecoin will reportedly be , which is registering as a money transfer operator. It will be a fully collateralized stablecoin, backed one-to-one with bank deposits and Japanese government bonds.

is also considering issuing its own yen-pegged stablecoin. Like JPYC’s, it would be fully collateralized with government bonds and other liquid assets, and aimed at use cases such as corporate settlements and global remittances.

Monex’s potential entry is especially notable. As a publicly traded company with subsidiaries including Tradestation and Coincheck — together serving millions of users — it could bring scale and credibility to Japan’s nascent stablecoin market.

If realized, these initiatives would mark the yen’s long-awaited entry into the $270 billion global stablecoin market, which today remains overwhelmingly dominated by US-dollar tokens, especially Tether’s USDt () and Circle’s USDC ().

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Stablecoin adoption heats up in Japan

Tezuka’s company, Startale, has pushed for greater stablecoin adoption in Japan, culminating in a , which also signed separate agreements with USDC issuer Circle and payments developer Ripple.

As part of the collaboration, SBI is working with Startale to build a platform for tokenized stocks and other real-world assets.

“The goal is to give institutional and retail investors the tools to trade tokenized assets, including US and Japanese native stocks, with true 24/7 access, near-instant cross-border settlements, and fractional ownership for greater accessibility,” Tezuka told Cointelegraph. 

Beyond tokenization, Startale is also focused on expanding corporate use of stablecoins by improving liquidity.

“The next step is programmable treasuries: using stablecoins alongside tokenized assets for automated FX hedging, conditional payments, and real-time capital allocation,” Tezuka said.

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