For most of 2023 and 2024, "wait for regulatory clarity" was a reasonable position for fintech compliance teams evaluating stablecoin payment products. The EU regulatory framework was still being finalised. US stablecoin legislation had stalled multiple times. The application of the Travel Rule to stablecoin transfers varied by jurisdiction and remained contested in several key markets.
That period is over. MiCA is fully in force across the EU. The GENIUS Act has advanced further than any previous US stablecoin legislation. The Financial Action Task Force has published clear guidance on applying Recommendation 16 to virtual asset transfers, including stablecoins. The regulatory landscape for stablecoin payments in 2026 is the most defined it has ever been, and for neobanks and digital wallets, that definition is a green light, not a barrier.
This post is not legal advice. It is a practical orientation to what the current regulatory environment requires, what it does not, and how a platform like WalletConnect Pay, which is compliant by design, materially changes how much compliance work your team needs to do.
MiCA: what it covers and what it means for checkout payment facilitation
The Markets in Crypto-Assets Regulation is the EU's comprehensive framework for crypto-asset markets. It covers the issuance of crypto-assets to the public, the trading and exchange of crypto-assets, and the provision of crypto-asset services. For neobanks and digital wallet platforms building stablecoin checkout and merchant payment products, the most directly relevant provisions concern:
- The classification of stablecoins as either electronic money tokens (EMTs) or asset-referenced tokens (ARTs)
- The service categories that constitute crypto-asset services and require CASP authorisation
- The ongoing obligations for platforms that facilitate crypto-asset transfers, including at point of sale and online checkout
USDC and USDT, the two stablecoins with the greatest payment volume in European markets, are classified under MiCA as EMTs when issued by EU-authorised entities. Circle, which issues USDC, has obtained an electronic money institution licence in France, making USDC fully MiCA-compliant for EU payments. For neobanks building checkout payment products on WalletConnect Pay, USDC is a primary supported stablecoin for EU payment flows, which means the asset-side compliance question is addressed at the infrastructure level.
For platforms facilitating stablecoin payments rather than issuing or custodying stablecoins, the primary regulatory question is whether the activity requires CASP authorisation. The consensus across major EU member states is that facilitating stablecoin transfers, including checkout payments, falls within CASP scope. However, platforms already holding an e-money institution licence may find their existing authorisation covers some of this activity depending on the specific service design and jurisdiction.
Key questions neobanks and digital wallets need to answer before launching under MiCA:
- Does the service design require CASP authorisation or is existing e-money/payment institution licencing sufficient?
- Which EU member states does the platform intend to serve, and what are the national implementation details in those jurisdictions?
- Does the platform custody stablecoin assets, and if so, what additional obligations apply?
- How will the platform handle the distinction between MiCA-compliant stablecoins like USDC and those without EU regulatory status?
The GENIUS Act: what it means for US-facing platforms
The Guiding and Establishing National Innovation for US Stablecoins Act, known as the GENIUS Act, is the most substantive US stablecoin legislation to date. The Act establishes a federal licensing framework for stablecoin issuers, defines what constitutes a payment stablecoin, and sets out reserve and disclosure requirements.
For digital wallet and neobank platforms enabling stablecoin checkout payments in or serving the US market, the most significant implications are:
- Platforms facilitating checkout payments will need to ensure they are using stablecoin issuances that meet the Act's definition of payment stablecoins
- The Act's money transmission provisions affect how stablecoin payment facilitation is classified at state level, which varies significantly
- GENIUS Act compliance may satisfy some but not all state money transmitter licence obligations that currently apply to crypto-adjacent payment products
The GENIUS Act does not make stablecoin payment facilitation simple in the US regulatory context. There is still meaningful state-level complexity. What the Act does is establish a federal framework that removes the fundamental uncertainty that previously made it difficult for neobanks to build a durable compliance position around stablecoin products.
Travel Rule and FATF Recommendation 16
FATF Recommendation 16 requires financial institutions and virtual asset service providers to collect and transmit originator and beneficiary information alongside transfers above a defined threshold. In the EU under MiCA's Travel Rule implementation, the threshold for stablecoin transfers is 1,000 EUR. Below this threshold, basic information must still be collected but does not need to be transmitted unless requested.
For neobanks and digital wallets facilitating stablecoin checkout payments, Travel Rule compliance involves:
- Collecting full originator information for outgoing payments, including name, account identifier, and where applicable, physical address
- Obtaining and verifying beneficiary information, including merchant identity, before completing the checkout transaction
- Transmitting this data to the merchant's VASP or payment processor where applicable
- Implementing screening processes to ensure transactions do not involve sanctioned addresses or entities
How WalletConnect Pay is built for the regulatory environment
Infrastructure choices have a direct and material impact on how much compliance work building a stablecoin payment product actually requires. A neobank integrating payment tools built without regulatory requirements in mind will spend significantly more time on compliance than one integrating infrastructure designed with those requirements as a first principle.
WalletConnect Pay is compliant by design. The platform is built specifically to support stablecoin checkout and merchant payment use cases for regulated PSPs, neobanks, and digital wallet operators, not adapted from a DeFi or exchange context. According to WalletConnect Pay's own documentation, balance checks, routing, and compliance steps including screening and KYC/KYT are completed before a payment is confirmed, so providers can keep the same operational and compliance controls they rely on today.
In practical terms: full audit trails and data visibility for operations and reporting are standard. Payment compliance requirements, including required customer and transaction information capture and screening, are aligned with common PSP compliance workflows. Travel Rule data handling is built into the payment infrastructure, not added as a separate layer by the integrating platform.
For compliance teams assessing integration risk, this means the architecture has been built to accommodate their requirements rather than requiring them to retrofit compliance onto a tool that was never designed for it. That translates directly to a faster compliance assessment and a lower ongoing overhead after launch.
Want to understand what compliant stablecoin checkout infrastructure looks like? Read the WalletConnect Pay documentation or speak directly with the team.