Deloitte expects 2025 to be “the year of the payment stablecoin”

In Deloitte 2023 publication, Engaging with Stablecoins, and Deloitte inaugural piece in 2021, So You Want to be a Stablecoin Issuer, the consulting company explored the dynamics of this innovative digital asset class, highlighting complexities, market disruptions, and the evolving regulatory landscape both in the United States and globally.

Fast forward to 2025, and multiple forces appear to be encouraging “traditional” financial (non-crypto-native) companies to consider becoming stablecoin issuers, from the recent surge and market capitalization and transaction volume of fiat-backed stablecoins, combined with signaling from the new administration, banking regulators and movement in the U.S. Congress towards a “payment stablecoin” (“PSC”) law and regulatory regime. A potential payment stablecoin issuer (“PSCI”) should strategically assess market opportunities, regulatory requirements, and required capabilities to successfully launch a PSC.

Deloitte anticipate 2025 to be different than 2021 for a few reasons:

. The administration’s stated priority in supporting USDbacked stablecoins

. Forthcoming legislation with the potential to create further regulatory clarity

. Early signs of market adoption and market activity with banks looking to become issuers and activity among venture capital and private equity firms

As a result, Deloitte expects 2025 to be “The year of the payment stablecoin,” potentially creating new opportunities for a wide range of market participants.

In this next installment in our stablecoin series, we will delve deeper into the current state of pivotal regulatory developments while also presenting a revised “impact and response framework,” grounded in leading industry practices. This framework can serve as a selfassessment tool for financial service companies and others that are starting from “the ground up” in building out capabilities to support the issuance of PSCs.

Recent developments

Administration developments
Since taking office, the Trump administration has begun to reframe US policies toward the digital asset industry. In an early step, President Trump signed an executive order entitled “Strengthening American Leadership in Digital Financial Technology” that called for a new approach and set a 60-day deadline for agencies to identify any relevant past guidance on digital assets.
With respect to PSCs, the executive order put explicit emphasis on promoting the global growth of dollar-backed PSCs. In terms of policy details for achieving this end, the new administration is still formulating an approach.

Regulatory developments
To date, federal agencies have taken some initial steps to rescind and adjust past guidance and adjust their supervisory approach and reevaluate their approach to cryptocurrency.
On March 7, 2025, on top of the slew of recent administrative developments, the Office of the Comptroller of the Currency (OCC) rescinded its Interpretive Letter 1179 (which outlined the agency’s supervisory nonobjection process for banks to engage in digital asset activities) and reaffirmed that national banks may engage in crypto-asset custody, distributed ledger, and stablecoin activities, as discussed in prior interpretive letters.

Legislative developments
As of February 2025, three bills have been introduced in Congress that would set up a legal and regulatory framework for “payment stablecoins”: (1) the GENIUS Act introduced in the Senate by Senator Bill Hagerty (R-TN), with some bipartisan co-sponsorship; (2) the Stablecoin Transparency and Accountability for a Better Ledger Economy (STABLE) Act introduced in the House by Representative French Hill (R-AR); and (3) an as yet unnamed bill introduced in the House by Representative Maxine Waters (D-CA).

The probability of PSCs legislation being enacted in 2025 has increased significantly, which could drive more companies to issue PSCs and encourage others to leverage them within their business operations. This political shift is also expected to influence the regulatory landscape, reinforcing legitimacy of the underlying technology and product, and creating opportunities for new market entrants.

In Congress, each of the three PSC bills that has been introduced establishes a federal regulatory framework for PSCs, which would be a critical step. Common elements of these bills include one-to-one backing of reserve assets to tokens in circulation, restrictions on asset types for PSC reserves, and regular auditing and certification of reserves. As noted above, permitted PSC issuers are limited under these bills to nonbank entities (NBEs) and insured depository institution (IDI) subsidiaries.

For more details download the report: „2025 – the year of payment stablecoins„