Stablecoins and fiat clearing are discussed as separate markets. The infrastructure they require is converging toward a single model. The GENIUS Act requires stablecoin issuers to maintain 100% reserves in segregated custody. The FCA's safeguarding regime requires payment firms to hold client funds in segregated accounts with daily reconciliation. PSD3 prohibits commingling at receipt. Each framework arrives at the same conclusion: institutions that hold other people's money should not be lending it, mixing it, or tracking it with internal ledgers.
The convergence is not theoretical. Stablecoin supply grew 50% in 2025, with transaction volumes rising 83% to exceed $4 trillion in the first half of 2025 alone, according to TRM Labs. Total stablecoin market capitalisation now exceeds $200 billion. For platforms operating in both fiat and digital environments, the custody architecture does not need to be duplicated. It needs to be unified.
The regulatory parallel
The overlap between fiat safeguarding and stablecoin reserve requirements is not a metaphor. It is a direct regulatory parallel. The GENIUS Act requires 100% reserve backing in high-quality liquid assets, segregation of customer assets, prohibition on rehypothecation except for short-term liquidity, monthly CEO and CFO certifications, and stablecoin holder super-priority claims in bankruptcy. Reserve assets must be identifiable, segregated, and not commingled. The Act takes effect by January 2027, with implementing regulations required by July 2026.
The FCA's PS25/12, effective May 2026, requires segregated safeguarding accounts, daily reconciliation, resolution packs, annual audits, named senior manager accountability, and monthly regulatory returns. PSD3, which reached political agreement in November 2025, requires segregation at receipt with no commingling and is moving toward a statutory trust framework for safeguarded funds. The differences between these regimes are procedural: different reporting frequencies, different supervisory bodies, different terminology. The substance is identical.
This convergence is not coincidental. The failures that prompted each framework share the same structural cause: institutions that held client funds deployed those funds for their own benefit, tracked ownership through internal ledgers rather than structural segregation, and left customers unable to recover their money when the institution failed. The Synapse collapse in fiat, the FTX collapse in digital assets, and the UST/LUNA depegging each demonstrated the same vulnerability from different angles. Regulators reached the same infrastructure conclusion independently.
What convergence means for platforms
Platforms that process both fiat payments and stablecoin transactions, or that plan to integrate stablecoin settlement into their cross-border operations, face an infrastructure choice. They can build separate custody architectures for each: one framework for fiat safeguarding under FCA and PSD3 rules, another for stablecoin reserves under the GENIUS Act and MiCA. Or they can build once, on infrastructure that satisfies the requirements of both. The unified approach is more efficient because the requirements are substantively the same.
A custody infrastructure that provides named custody accounts with structural segregation, supports daily reconciliation, and maintains auditable records satisfies the safeguarding requirements for both fiat and stablecoin holdings. The account structure is the same. The segregation is the same. The reporting obligations differ in frequency and format, but the underlying data and custody architecture serve both.
Circle's 2025 year in review illustrates the institutional trajectory: USDC's market cap rose from $44 billion to $77 billion during the year, with adoption accelerating across banking systems, enterprise payments, and tokenised settlement. Circle's successful NYSE IPO, raising $1.05 billion at a valuation approaching $19 billion, signalled that regulated stablecoin infrastructure has moved from experimental to investable. For platforms evaluating stablecoin integration, the infrastructure question is not whether to build for compliance. It is whether to build it alongside or on top of their existing fiat safeguarding infrastructure.
The infrastructure layer beneath both
A specialist clearing institution that operates with 100% reserves, no lending book, and segregated custody is already built on the model that both fiat and stablecoin regulators are mandating. The extension from fiat custody to stablecoin reserve custody is architectural, not transformational. The key capabilities required are specific:
MAS's BLOOM initiative in Singapore is exploring precisely this convergence, testing settlement in tokenised bank liabilities and regulated stablecoins. Hong Kong's Project Ensemble is piloting real-value transactions using tokenised deposits, with the RTGS system facilitating interbank settlement.
Building once for both
The practical advantage of unified infrastructure is cost avoidance. Building separate custody systems for fiat and stablecoin, each with its own reconciliation, reporting, compliance, and audit processes, doubles the infrastructure investment without doubling the capability. Building once, on infrastructure that satisfies both frameworks, costs less and scales better. As the number of regulated stablecoin issuers grows, the platforms that already have compliant custody infrastructure in place will be positioned to serve them without additional builds.
For fintech and PSP platforms evaluating stablecoin integration for cross-border settlement, the infrastructure decision should start with custody. If the custody architecture already satisfies fiat safeguarding requirements through structural segregation and multi-currency clearing, extending it to stablecoin reserve custody is an incremental step rather than a new build. The compliance model is the same. The custody structure is the same. The only difference is whether the underlying asset is fiat currency or a tokenised instrument.
Lorum provides clearing, custody, and cash management infrastructure across 30+ markets, including stablecoin wallets, within the same regulated framework. The convergence between fiat and digital asset custody requirements is already reflected in enacted legislation across the US, UK, and EU. The infrastructure should reflect it too. Platforms that build on unified infrastructure today are positioned for both regimes from day one.
