Although the U.S. "GENIUS Act" is hailed as a market catalyst for stablecoin adoption, Japan's early reforms show another side: clear regulation does not automatically translate into immediate practical utility.
Japan has the world's first comprehensive stablecoin system in 2023, but adoption has been lukewarm. Licensed issuers exist on paper, but there is no thriving yen stablecoin economy.
In an interview with Cointelegraph, Takashi Tezuka, the national manager of Web3 infrastructure developer Startale Group, stated that the adoption gap between the U.S. and Japan reflects philosophical differences in regulatory design.
"The GENIUS Act has received a mixed response of relief and curiosity," Tezuka said, "because the U.S. is finally catching up to what Japan did two years ago—establishing a comprehensive legal framework around stablecoins."
According to Japan's 2023 amendment to the Payment Services Act, only licensed banks, trust banks, and registered remittance agents are allowed to issue stablecoins.
In contrast, the U.S. approach under the GENIUS Act is more open: not only banks but also federally licensed non-bank companies can pursue stablecoin issuance as long as they meet reserve and compliance standards.
This highlights the philosophical divide. "Japan prioritizes system stability over the speed of innovation, while the U.S. is sending a stronger signal of market openness," Tezuka pointed out.
However, this gap may not last long. Japan's infrastructure-first strategy "reflects broader industry signals—global players are building infrastructure to support programmable enterprise-level capital markets, and Japan's cautious, infrastructure-first mindset positions the country to compete when the regulatory environment matures."
After laying the regulatory groundwork over the past two years, Japan will approve its first yen stablecoin this fall, opening the door for blockchain remittances and payments in its national currency.
Reportedly, the first stablecoin will be issued by local fintech company JPYC, which is registering as a remittance operator. This will be a fully collateralized stablecoin, backed one-to-one by bank deposits and Japanese government bonds.
Tokyo-based Monex Group is also considering issuing its own yen-pegged stablecoin. Like JPYC's stablecoin, it will be fully collateralized by government bonds and other liquid assets, aimed at use cases such as corporate settlements and global remittances.
Monex's potential entry is particularly noteworthy. As a publicly traded company, its subsidiaries include Tradestation and Coincheck—serving millions of users—it could bring scale and credibility to Japan's emerging stablecoin market.
If realized, these initiatives would mark the long-awaited entry of the yen into the $270 billion global stablecoin market, which is currently overwhelmingly dominated by dollar tokens, particularly Tether's USDT and Circle's USDC.
Tezuka's company Startale has been advocating for greater stablecoin adoption in Japan, recently forming a partnership with local financial giant SBI, which has also signed separate agreements with USDC issuer Circle and payment 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 provide tools for institutional and retail investors to trade tokenized assets, including U.S. and Japanese domestic stocks, with true 24/7 access, near-instant cross-border settlement, and greater accessibility through fractional ownership," Tezuka told Cointelegraph.
In addition to tokenization, Startale is also focused on expanding corporate use of stablecoins by improving liquidity.
"The next step is programmable treasury: using stablecoins alongside tokenized assets for automated forex hedging, conditional payments, and real-time capital allocation," Tezuka said.
Related: Japan's Web3 revolution is timely: The Prime Minister attends the WebX summit, and major exchanges compete for the new market.
Original article: Japan Leads the Way in Stablecoin Rulebook—Why is the U.S. Pulling Ahead?
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