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Not all stablecoins are created equal

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While most stablecoins track the USD, they vary in terms of structure, risk, and regulation. Our latest report on digital assets unpacks their differences – from regulated status and design models to the degree of transaction monitoring and control.

The illusion of uniformity. Stablecoins are often treated as a homogenous form of tokenised money. In practice, they are anything but. While approximately 99% of stablecoin market cap relates to tokens pegged against the USD, this apparent uniformity can mask key differences in terms of reserve quality, legal claims, regulatory oversight, and redemption mechanics. The lack of fungibility is becoming more important as stablecoins move beyond crypto-native use cases and into mainstream financial activity.

Differences go beyond “regulated” versus “non-regulated”. One key fault line is emerging between regulated (or licensed) stablecoins and those operating outside formal regulatory frameworks. However, this single metric understates the complexity. Even within regulated stablecoins, there are evident design divergences. Some regulators create an environment where stablecoins can move towards cash-like, bearer instruments, prioritising transferability and global usability. Other regulators prefer stablecoins to be structured as tracked or permissioned forms of digital money, embedding identity, and compliance. There are also other differences between stablecoins, including issuer type and reserve composition.

This divergence is not inherently problematic. Different models serve different purposes. Regulated stablecoins are likely to dominate in institutional finance, payments, and corporate treasury where transparency and compliance are critical. Less-regulated stablecoins continue to play a central role in crypto market liquidity, financial access in emerging markets, and on-chain innovation. Their use is not synonymous with illicit activity but often reflects gaps in regulated alternatives. However, the lack of true fungibility introduces risks. These include fragmented liquidity, constraints on cross-border use, uneven redemption rights, and increased operational complexity.

In stress scenarios, differences may become more acute. For investors and corporate treasurers, stablecoins should not be treated as entirely interchangeable. What appears to be a simple dollar equivalent may, in practice, carry distinct risks, constraints, and opportunities.

We believe divergences may narrow. More cautious regulatory regimes may become more accommodating as familiarity grows, while permissive regimes may introduce additional safeguards. The likely outcome is not full harmonisation but a functionally differentiated system with different stablecoins for different uses.

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Talking Digital Assets

In the latest edition of our Digital Assets podcast series, HSBC’s Aline van Duyn talks to Daragh Maher about the various forms stablecoins can take, how they differ from tokenised deposits, as well as the risk and regulation around them.

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