How to Use Stablecoins in Humanitarian Aid: A Practical Framework

Disclaimer
This paper is a practical framework emerging from the 2025 Humanitarian Aid Payments Council. It reflects input from multiple Council members, but responsibility for any errors or interpretations rests with MarketImpact Digital Solutions Ltd.

A Practical Framework Emerging from the 2025 Humanitarian Aid Payments Council
Key Takeaways
Stablecoins are regulated money: Under the EU’s MiCA framework, E-Money Tokens (EMTs) are legally recognised as e-money, with enforceable redemption rights.
Cash or voucher, not a new modality: For humanitarians, stablecoins map directly onto ECHO’s CVA framework—cash if liquid and unrestricted, vouchers if restricted.
Direct-to-beneficiaries: Possible in contexts with liquidity and enabling regulation (e.g., Afghanistan’s AFN-pegged stablecoin), but still high-risk and context-dependent.
Treasury rails: Already delivering impact by overcoming banking blockages, preserving donor value in distorted FX markets, and ensuring liquidity reaches country offices.
Partners and vendors: Stablecoins enable faster, cheaper payments to local NGOs and suppliers (e.g., Sudan, Myanmar), strengthening localisation and supply chain continuity.

Two weeks ago in Berlin, the Algorand Foundation convened the Humanitarian Aid Payments Council, bringing together UN agencies, major NGOs, financial service providers, and blockchain specialists to tackle a pressing question: how can digital assets improve humanitarian aid delivery in the world’s most complex operating environments?

As a council member, MarketImpact Digital Solutions Ltd participated in two days of intensive discussions alongside UNHCR, WFP, Circle, Visa, Mercy Corps Ventures, and others. In the session on "Addressing systemic barriers to bringing aid on-chain," one question emerged as fundamental: Are stablecoins money? And if so, how should humanitarian organizations classify them within existing frameworks?

For years, this question has lingered in the abstract, with humanitarian practitioners, donors, and technologists offering different interpretations. Some viewed stablecoins as speculative crypto, others as digital cash, and still others as something entirely new requiring new categories and controls.

Now, however, we have legal clarity. The European Union's Markets in Crypto-Assets Regulation (MiCA), which came into effect for stablecoins on 30 June 2024, provides definitive answers. E-Money Tokens (EMTs) that meet MiCA's requirements are legally recognized as e-money, not just tokens that behave like money, but money in the eyes of the law, with enforceable redemption rights.

This paper, developed by MarketImpact Digital Solutions Ltd with input from multiple council members, attempts to translate that regulatory clarity into practical guidance for the humanitarian sector. Building on the council's discussions and MarketImpact's expertise in digital transformation for humanitarian operations, we map MiCA's legal framework onto ECHO's established Cash and Voucher Assistance (CVA) categories. The result is a clear classification system: regulated stablecoins are either cash or vouchers, depending on how they're implemented.

For humanitarian actors seeking to leverage blockchain's speed, transparency, and efficiency while maintaining donor confidence and regulatory compliance, this framework we hope provides the missing link between innovation and implementation.

What Are Stablecoins Under MiCA?
For humanitarian actors, the first step in making sense of stablecoins is to understand how the European Union now defines and regulates them. This is not a matter of marketing or opinion, it is written into law under the Markets in Crypto-Assets Regulation (MiCA), which became enforceable for stablecoins on 30 June 2024.

Two categories, but only one humanitarian-relevant

MiCA divides stablecoins into two families:

E-Money Tokens (EMTs): tokens pegged to the value of a single official currency, such as the euro or the U.S. dollar.
Asset-Referenced Tokens (ARTs): tokens backed by a basket of assets (e.g., multiple currencies, commodities, or other instruments).

For humanitarian finance, the most important category under MiCA is E-Money Tokens (EMTs).

Why EMTs Matter, Authorisation, Supervision, and Legal Status
Under the EU’s MiCA regulation, E-Money Tokens (EMTs) are the most relevant type of stablecoin for humanitarian finance. MiCA states that EMTs “shall be deemed to be electronic money” under the EU’s E-Money Directive (EMD2). This means they are legally recognised as e-money, a decisive shift from stablecoins being seen as unregulated “crypto.”

EMTs are not identical to traditional e-money. MiCA introduces specific provisions reflecting their crypto-asset nature, so EMTs sit within two overlapping regimes: as e-money under EMD2 and as crypto-assets under MiCA. In practice, EMTs share core e-money protections (notably par-value redemption) and comply with additional MiCA safeguards.

To qualify, issuers must meet strict authorisation and supervision requirements:

Licensing: hold an Electronic Money Institution (EMI) licence or be a credit institution (bank)
Reserves: maintain fully backed, high-quality reserves in the same currency as the token.
Safeguarding: hold reserves in segregated accounts, legally protected from the issuer’s balance sheet.
Oversight: undergo audits and ongoing national/EU supervision.

Terminology used in this paper: “MiCA-regulated E-Money Tokens” means EMTs issued by an EMI-licensed entity (or bank) that has notified a MiCA EMT white paper and complies with all MiCA obligations.

For humanitarian actors, the implication is clear: MiCA-regulated E-Money Tokens can be treated as a regulated digital equivalent of cash. Unlike unregulated tokens, they carry donor-level compliance assurances, consumer protection, and enforceable redemption rights, the essential elements of trust for humanitarian operations.

This is the key point: under MiCA, an EMT is not merely “crypto behaving like money.” It is money in the eyes of the law, with legally recognized e-money status and enforceable rights.

Circle and Quantoz: First movers under MiCA
The most important development so far is that Circle, the company behind USDC and EURC, secured authorisation in France in July 2024. Circle’s French entity now operates as a licensed Electronic Money Institution (EMI) under MiCA.

USDC: pegged to the U.S. dollar, redeemable 1:1, backed by cash and short-term U.S. government securities.
EURC: pegged to the euro, redeemable 1:1, backed by equivalent euro reserves.
Legal status: both are legally e-money when issued by Circle France.
Redemption rights: holders can demand conversion into fiat currency at par value.

Alongside Circle, Quantoz Payments, based in the Netherlands, has also secured MiCA approval. Quantoz issues tokens such as EURQ (pegged to the euro) and USDQ (pegged to the U.S. dollar), following the same model: fully backed reserves, par-value redemption, and supervision under EU law.

MiCA’s safeguards require issuers of MiCA-regulated E-Money Tokens to:

Hold at least 30% of reserves as deposits at credit institutions, with the remainder in highly liquid, low-risk instruments in the same currency as the token.
Prohibit the payment of interest to token holders.
Guarantee redemption at par value.

Together, these provisions form the core consumer-protection pillars that distinguish MiCA-regulated tokens from unregulated alternatives.

Selecting an Issuer: Principles Over Logos

While Circle and Quantoz are the first movers, NGOs and donors should base their decisions on principles rather than brand names. Four pillars provide a useful guide:

Regulatory compliance – EMI or bank licence, MiCA EMT white paper, regulatory attestations.
Operational liquidity – depth of local off-ramps, FX stability, agent float.
Donor alignment – AML/CFT standards, reporting, auditability, transparency.
Programme feasibility – fit with country rules, partner capacity, service continuity.

Named examples like Circle and Quantoz illustrate the emerging category, but the decision to use a particular issuer should always be assessed against these pillars.

Why This Matters for Humanitarians
For the humanitarian sector, the significance is clear: we now have more than one donor-ready issuer. Circle’s USDC/EURC and Quantoz’s EURQ/USDQ demonstrate that MiCA is not just regulatory theory, it is shaping a growing ecosystem of MiCA-regulated E-Money Tokens.

Humanitarian actors are accountable not only for what they deliver but also for how funds are managed and transferred. Donors demand AML/CFT compliance, financial safeguards, and clear audit trails.

By using MiCA-regulated E-Money Tokens (e.g., issued by Circle or Quantoz), NGOs can show they rely on instruments legally recognised as e-money under EU law. This gives donors confidence that transfers meet familiar compliance, consumer-protection, and redemption standards—while enabling faster, more transparent digital delivery.

Note: MiCA’s EMT rules have applied in full since 30 June 2024. Transitional arrangements until mid-2026 apply only to CASPs, not to EMT issuance.

The next step is to map these legal categories into ECHO’s operational framework, which governs how donors and NGOs classify assistance in practice.

ECHO’s Cash and Voucher Framework
Why ECHO’s Categories Matter
For humanitarian organisations, debates about “what counts as cash” or “whether digital tokens are money” can seem abstract. But for donors like the European Commission’s Directorate-General for European Civil Protection and Humanitarian Aid Operations (ECHO), these categories are concrete. They shape programme design, determine what counts as eligible expenditure, and set the benchmarks against which assistance is judged.

That is why any discussion of stablecoins in humanitarian contexts has to be anchored in ECHO’s Cash and Voucher Assistance (CVA) policy framework. Fortunately, this framework is clear, consistent, and well-established. The definitions first set out in 2013 have been reaffirmed and updated in subsequent policy documents, most notably the 2022 Thematic Policy Document No. 3 – Cash Transfers.

Understanding how ECHO defines cash, vouchers, and in-kind assistance is essential before we can sensibly map stablecoins into these categories.

ECHO’s CVA Foundations and Today’s Defaults
ECHO’s 2013 Humanitarian Aid: Cash and Vouchers – Guidance for Implementation marked the moment cash assistance was fully normalised in European humanitarian policy. It drew clear lines between cash transfers, vouchers, and in-kind aid; set out how each modality should be designed and monitored; and, crucially, framed cash not only as efficient but as dignifying—because choice rests with people, not programmes.

Nearly a decade later, Thematic Policy Document No. 3 – Cash Transfers (2022) reaffirmed that direction and made it sharper: where markets function and delivery systems exist, cash should be the default. Vouchers and in-kind assistance remain valid tools, but are second-best options when cash is impractical or the risks are too high. The 2022 policy also codified minimum expectations around accountability to affected people, value for money, and risk management (including fraud, protection, and AML/CFT).

Across these documents the definitions are stable. Cash transfers are unrestricted payments—physical or digital—that people can convert and spend as they choose. Vouchers provide value that is limited to certain goods, services, or merchants—restriction is their defining feature. In-kind assistance delivers goods or services directly, with no transfer of financial value. In short: liquidity and choice define cash; restriction defines vouchers.

The essence of ECHO’s distinction is not about form but function.

If the transfer is liquid and beneficiaries can use it without restriction, it is cash.
If the transfer is restricted, whether by donor rules, provider arrangements, or technical design, it is a voucher.
If no value is transferred and only goods or services are delivered, it is in-kind.

This principle matters because it keeps the focus on the beneficiary experience. From their perspective, what matters is not whether value is digital or physical, but whether they can use it freely.

The Liquidity & Redemption Test
In humanitarian aid, the fundamental difference between cash and a voucher is not the technology used but the function in a person’s hands. This can be determined by a simple but powerful operational standard: the Liquidity & Redemption Test.

It asks two fundamental questions:

Can the assistance be converted into local currency at its full face value? For example, does a €20 digital token reliably yield €20 in hand?

Can the beneficiary spend that value freely, anywhere, on anything they identify as a priority? Freedom of choice, deciding whether to spend on rent, food, transport, or medicine, is the cornerstone of cash assistance. If value is restricted to certain shops, certain categories of goods, or cannot be converted into local currency, it functions as a voucher.

If the answer to both questions is yes, the assistance functions as cash. If the answer to either is no, it functions as a voucher.

If redemption itself is too thin, costly, or unreliable, the modality may not be programmatically viable at scale, regardless of its legal form.

Think of it this way: a €20 banknote passes the test, it can be exchanged anywhere, at face value, with full choice. A €20 gift card for a specific supermarket fails, the nominal value is the same, but the freedom is not.

This distinction holds true across all delivery mechanisms, whether physical banknotes, mobile money, or MiCA-regulated E-Money Tokens. The test always comes back to two core principles: liquidity and choice. Getting this classification right is essential for programme design, donor reporting, and most importantly, upholding the dignity of the people we serve.

Smart Contract Restrictions: A New Form of Voucher
One of the distinctive features of digital money is its programmability. Through smart contracts, rules can be embedded directly into a token—limiting how it can be used. For example, a token might only be spendable at selected merchants, it might block cash-out into local currency, or it might prohibit purchases of certain items such as alcohol or tobacco.

From a technical perspective, this programmability looks innovative. From a humanitarian perspective, however, it changes the nature of the transfer. The line between cash and voucher in ECHO’s framework is clear: cash is unrestricted value that people can redeem or spend as they choose, while any restriction turns the transfer into a voucher. The same €20 token could therefore function as cash in one programme, if it is liquid and unrestricted, or as a voucher in another, if its use is confined.

Restrictions are not only written into code. They can also arise from the ecosystem—thin acceptance networks, weak off-ramps, or limited merchant participation—or from programme design, where donors impose conditions or vendor agreements limit choice. In each case, the effect is the same: the beneficiary’s freedom is constrained.

That said, programmable stablecoins do introduce a new kind of voucher. Compared to legacy voucher platforms, which often depend on heavy reconciliation and bespoke vendor contracts, smart contract–based vouchers can be cheaper to operate, easier to switch between restricted and unrestricted modes, and more transparent, since the rules are visible in code rather than buried in contracts.

The principle remains unchanged: restriction transforms cash into a voucher. But in digital form, vouchers may be lighter, more flexible, and more transparent—even if they still limit the dignity of full choice.

Mapping MiCA → ECHO and Key Use Cases
From Principles to Practice
Up to this point, we have laid the groundwork. MiCA provides legal definitions of stablecoins, recognising MiCA-regulated E-Money Tokens as e-money under EU law. ECHO provides clear humanitarian categories, cash, vouchers, in-kind, based on liquidity and restriction.

The task now is to bring these frameworks together. This is not (yet) donor policy. It is an interpretive framework, a way for humanitarians to think about stablecoins using the categories they already know. Once this mapping is clear, we can explore the two main ways stablecoins are likely to be used in humanitarian operations: direct-to-beneficiaries and treasury/FSP payments.

Mapping MiCA → ECHO (Interpretive Framework)
It is important to stress: what follows is interpretive, not prescriptive. Donors have not yet issued formal guidance on how stablecoins should be reported within CVA categories. But by applying ECHO’s principles to MiCA’s definitions, we can build a framework that makes sense.

MiCA-regulated E-Money Tokens (unrestricted) → Cash

When an EMT is legally recognised, liquid at par value, and spendable without restriction, it functions exactly like cash in humanitarian terms.
Example: EURC issued under Circle France’s license, or EURQ from Quantoz, provided beneficiaries can cash out or spend freely.

MiCA-regulated E-Money Tokens (restricted, incl. smart-contract rules) → Voucher

The same tokens, if restricted, e.g., by coding that only allows spending at selected merchants or blocks cash-out, must be treated as vouchers.
The restriction mechanism (contract, donor rule, or smart contract) doesn’t matter. The effect is what counts.

Asset-Referenced Tokens (ARTs) → Cash-like with caveats

ARTs pegged to baskets of assets could in principle function like cash, but regulatory uncertainty and donor caution make them risky. For now, they should be treated as cash-like but requiring caveats and strong justification.

This mapping gives NGOs a clear lens. The same token could be reported as cash or voucher depending on how it is delivered. The category follows the function, not the form.

With this interpretive framework in place, the question becomes: how might UN agencies, INGO, Redcross Movement, and NGOs actually deploy these tokens in real-world operations?

Humanitarian Use Cases for Stablecoins
Research and feedback from operational actors show that, as of 2025, there are two distinct ways humanitarian organizations are beginning to use stablecoins. The first is as the transfer instrument itself, delivered directly to affected households as part of Cash and Voucher Assistance (CVA). The second is as treasury rails, moving value behind the scenes from HQ to country offices, partners, and vendors when traditional banking channels are blocked or distorted.

Taken together, these two approaches cover the full humanitarian finance chain—from the initial cross-border transfer to the last mile of delivery. This section explores both categories: Direct-to-Beneficiaries (CVA Delivery) and Treasury & B2B (Back-End Infrastructure).

1. Direct-to-Beneficiaries (CVA Delivery)
   In this model, an a Humantirian Actor transfers a regulated stablecoin such as EURC or USDC issued under an EMI license directly into a beneficiary’s wallet. The household can then cash out into local currency or spend digitally, depending on the available ecosystem.

Classification follows ECHO’s framework. If beneficiaries can redeem at par value and use the funds without restriction, it counts as cash. If redemption is blocked or limited, for example, to approved merchants or categories, it functions as a voucher.

The advantages are clear: instant settlement with lower transfer and FX costs, transparent flows with donor-level auditability, and programmable features such as conditional or time-bound disbursements.

The risks are equally real: dependence on smartphones, digital literacy, and reliable network coverage; limited liquidity in agent networks for large-scale cash-outs; and uncertainty over whether legal redemption rights extend into fragile jurisdictions.

Scenario An NGO transfers a regulated stablecoin, such as EURC or USDC issued under an EMI license, directly into a beneficiary’s wallet. The household can then choose to cash out into local currency or spend digitally, depending on the available ecosystem.

Example – Afghanistan (HesabPay, 2023–2025)

Afghanistan’s financial system was left fragile after the Taliban takeover. International correspondent banks pulled out, domestic banks faced liquidity crises, and capital controls tightened. NGOs struggled to move funds into the country, while cryptocurrency trading was formally banned, creating compliance risks for aid actors seeking digital solutions.

HesabPay addressed this challenge by operating as a licensed Electronic Money Institution (EMI) and issuing a stablecoin pegged directly to the Afghan afghani (AFN). Unlike dollar- or euro-pegged tokens, this design meant there was no FX conversion step: one digital token always equaled one afghani, redeemable for cash through HesabPay’s network of local agents.

Humanitarian organisations piloting with HesabPay were able to send AFN stablecoins directly to beneficiary wallets. From there, households could cash out at par value in physical afghani notes, or spend digitally with participating merchants. For beneficiaries, the experience was simple and familiar—more like mobile money than “crypto”—but with stronger assurances of redemption and liquidity.

Reported benefits included:

Instant settlement of transfers, bypassing blocked or delayed bank wires.
Guaranteed one-to-one cash-out, protecting the full value of assistance.
On-chain transparency, providing donors with clear audit trails.
Programmability, allowing pilots of conditional or time-based disbursements.

Risks remained. Access depended on smartphones and reliable connectivity, and liquidity at agent locations had to be carefully managed to avoid cash-out bottlenecks. The shifting regulatory environment also raised questions about long-term enforceability of redemption rights.

The implication is clear: local-currency stablecoins can deliver true cash assistance in fragile contexts. By fixing tokens one-to-one with the afghani and guaranteeing redemption through licensed EMI infrastructure, HesabPay created a model that fits squarely within ECHO’s definition of cash—unrestricted, liquid, and beneficiary-centered.

2. Treasury & B2B (Back-End Infrastructure): Two Flows, Two Use Cases
   Use Case 1: Overcoming International banking blockages
   Process Flow 1: International → Country

The first challenge is simply getting funds into For NGOs, one of the hardest challenges is ensuring funds reach the operating environment when banking channels are blocked or distorted. Traditional cross-border transfers via correspondent banks are frequently delayed, rejected, or stranded due to sanctions filters, de-risking practices, or liquidity shortages.

With stablecoins, the model works differently. NGOs can on-ramp directly in their HQ jurisdiction, typically through a local bank transfer into a wallet they control (HQ or country office). From there, they have two options. At its simplest, the funds can be sent and off-ramped locally through vetted partners—banks, mobile money operators, or cash agents—giving immediate access to liquidity at real market FX rates. Alternatively, where programmes require more structure, NGOs can embed disbursement logic via smart contracts (for example, milestone-based releases or triggers linked to external data such as weather events). In both cases, local partners receive funds into self-custodial wallets and cash out through trusted off-ramps.

The key efficiency comes not from “faster cross-border transfers,” but from avoiding the international banking leg altogether. By on-ramping at HQ and connecting directly to local liquidity networks, NGOs preserve donor value, reduce settlement times from weeks to hours, and ensure continuity of programming in contexts where the formal financial system cannot be relied upon.In Sudan between 2023 and 2025, INGOs faced this problem acutely. Official FX rates were far below parallel market rates, creating massive value loss when converting donor funds through formal channels. Several NGOs piloted HQ-to-country stablecoin transfers, off-ramping through vetted fintech and hawala providers at real market FX. This preserved value, kept liquidity flowing to field teams, and enabled uninterrupted programming during a period when traditional banking channels were paralyzed.

The implication of both cases is clear: stablecoins are not only a faster rail, they are a donor-value protection tool, ensuring funds reach the operating environment in full, even under severe banking stress.

Example – Myanmar (2024–2025, Coala Pay )

Following the 2024 earthquake in Myanmar, international NGOs and foundations faced severe barriers in moving funds into the country. Correspondent banks introduced multi-week delays and, in some cases, rejected transfers outright due to heightened sanctions risk. Local NGOs, under pressure to respond rapidly, were left without liquidity to launch or scale their programmes.

A UK-based foundation piloted a different approach with Coala Pay. Instead of attempting a cross-border wire, the foundation on-ramped domestically in the UK: making a local bank transfer into a wallet under its own control. Once funds were in that wallet, Coala Pay’s smart contracts executed pre-agreed disbursement logic. This could be milestone-based or even triggered by external data sources (for example, weather-linked oracles).

The funds were received in the self-custodial wallet of a vetted local NGO partner. That NGO then off-ramped into Myanmar kyat through Coala Pay’s local partner network, primarily via KBZPay, one of the country’s largest mobile money providers. This avoided the international leg entirely and gave the partner reliable liquidity in local currency within days.

Implementer reports highlighted transformational gains:

Settlement time reduced by 99% (weeks to hours).
Transaction costs cut by more than 80%.
Over 10,000 households reached with rapid cash and voucher support.
Local value preserved, with 105% more purchasing power delivered compared to official-rate conversions.

The Myanmar case shows that efficiency came not from “faster international transfers” but from bypassing them altogether. By on-ramping at HQ, automating disbursement via smart contracts, and leveraging trusted local off-ramps, Coala Pay enabled donor funds to translate quickly and fully into frontline liquidity.

Use Case 2: Overcoming National banking blockages
Process Flow 2: Country → Country

Once funds are in-country, Humanitarian Actors must move value to local par, when international wires are delayed or rejected. Payment bottlenecks can halt operations even if donor funds are available.

Stablecoins allow country offices to settle instantly with vendors, bypassing blocked banking channels. This ensures continuity of supply chains, reduces the risk of stock-outs, and provides donors with auditable on-chain payment records. NGOs in multiple fragile contexts have used stablecoins to keep fuel, telecom, and WASH supply lines moving when bank wires failed.

Example – Sudan (NRC and Coala Pay, 2023–2025)

In Sudan, the collapse of the formal banking system combined with sanctions exposure and extreme liquidity shortages left both partners and vendors unable to receive international transfers. Even when funds were approved, correspondent bank blockages and slow settlement created bottlenecks that threatened frontline operations.

NRC piloted an alternative with Coala Pay. Like in Myanmar, the NGO did not attempt to push stablecoins across borders. Instead, NRC on-ramped domestically in its HQ jurisdiction via a local bank transfer to a wallet controlled by its country office. From there, Coala Pay’s smart contracts released funds into the self-custodial wallets of Sudanese NGO partners, according to pre-defined disbursement logic.

Local partners then off-ramped into Sudanese pounds through Coala Pay’s network, primarily via Bankak, one of the few functioning banks still facilitating liquidity, or into cash via vetted intermediaries. This allowed partners to access local currency at real market FX rates, bypassing the massive losses tied to Sudan’s official rates.

The results were significant:

Settlement times dropped by 99% (weeks to hours).
Transaction costs fell by 24%.
Liquidity at the frontline increased by 34%.

The same model was also applied to vendor payments, with stablecoins used to pay suppliers such as fuel distributors and WASH kit vendors when international wires were blocked.

Unlike HesabPay, which issues its own AFN-pegged stablecoin via a proprietary EMI wallet, Coala Pay uses only self-custodial wallets and acts as infrastructure: automating disbursement through smart contracts and connecting to off-ramps managed by trusted national partners. This makes it a treasury and B2B rail rather than a beneficiary-facing instrument, but one that has already proven decisive in keeping aid pipelines functioning in Sudan.

Together, these applications show how stablecoins can act as B2B infrastructure within fragile economies. By enabling faster, cheaper, and more reliable payments to partners and vendors, they preserve programme continuity, reduce costs, and strengthen localisation—all without changing the underlying humanitarian modalities.

The implication is clear: within-country, stablecoins are not a new form of assistance, but rather invisible rails that make existing CVA possible by ensuring that partners and suppliers remain funded and operational when banking systems collapse.

Key Takeaways
Classification follows function. Under ECHO’s framework, stablecoins are not a new modality. They are either cash (when liquid and unrestricted) or vouchers (when use is constrained).
Direct-to-beneficiaries. Stablecoins can, in principle, deliver assistance directly to households with speed, transparency, and programmability. But their success depends on smartphone access, digital literacy, agent liquidity, and regulatory clarity—making this a high-potential but high-risk pathway.
Treasury transfers. Stablecoins are already proving valuable behind the scenes. They enable NGOs to bypass blocked banking channels, preserve donor value in distorted FX markets, and deliver liquidity to country offices quickly and reliably.
Partners and suppliers. Within countries, stablecoins strengthen localisation and continuity. They allow NGOs to fund local partners and pay critical vendors even when traditional banking collapses, ensuring programmes and supply chains remain operational.

Bottom line: Stablecoins are not a new form of aid delivery but stronger rails for existing humanitarian finance. They make cash and voucher assistance faster, cheaper, and more resilient—often invisible to beneficiaries, but essential to keeping assistance flowing.

Donor Landscape Beyond the EU: United States and United Kingdom
The EU framework under MiCA now provides the clearest regulatory pathway for stablecoins, and ECHO has established operational categories for classifying humanitarian transfers. Yet most large NGOs also rely heavily on U.S., UK, and multilateral donors, making it essential to track these parallel landscapes.

United States
The U.S. now has a federal framework for stablecoins: the GENIUS Act (Guiding and Establishing National Innovation for U.S. Stablecoins Act), passed in July 2025. This Act brings stablecoins into the regulated financial perimeter, creating a licensing regime for payment stablecoin issuers.

Key requirements under the GENIUS Act include:

1:1 backing with U.S. dollar assets: reserves must consist of cash or short-term U.S. Treasuries, excluding other crypto-assets.
Redemption rights: holders have a legal right to redeem tokens at par, with issuers obliged to honor requests promptly.
No yield: issuers are prohibited from paying interest to token holders, distinguishing regulated stablecoins from investment products.
Oversight: large issuers fall under direct federal supervision, while states may regulate smaller issuers (up to $10 billion outstanding) if their frameworks meet federal equivalence tests.
Compliance obligations: issuers must implement robust AML/KYC controls, independent audits, monthly reserve attestations, consumer disclosures, and operational resilience measures (e.g., cybersecurity, disaster recovery).

For humanitarian finance, the implications are clear: only GENIUS-licensed, fiat-backed tokens are donor-ready. NGOs using unlicensed or offshore-issued stablecoins would face unacceptable compliance, solvency, and audit risks. Donors will expect evidence of:

Use of a GENIUS-authorized token.
AML/CFT safeguards in line with U.S. regulations.
Proof that redemption at par is practical in the operating environment.

At the same time, the humanitarian policy environment in Washington is unsettled. With the closure of USAID in mid-2025 and the transfer of assistance portfolios to the State Department, funding frameworks are shifting. Practitioners report a trend toward “sectoral labeling”: while transfers may remain unrestricted at the beneficiary level, proposals and reporting are expected to frame assistance against sectoral outcomes (e.g., food, shelter, WASH). This appears to extend the Bureau of Population, Refugees, and Migration’s (PRM) sector-oriented approach into broader humanitarian cash programming.

Unlike MiCA, the GENIUS Act leaves some open questions — such as how secondary market transfers are supervised, or where issuer liability ends when tokens move across wallets. For NGOs, this means compliance risk assessments will remain essential, even with a federal licensing regime in place.

United Kingdom
The UK is in the late stages of standing up a payments-stablecoin regime across HM Treasury (HMT), the Financial Conduct Authority (FCA), and the Bank of England (BoE).

Legislative & policy track (HMT). On 30 October 2023, HMT set out the policy to bring fiat-backed stablecoins into the UK regulatory perimeter—covering both their use in payment chains and the activities of issuance and custody when carried out in or from the UK. On 29 April 2025, HMT published a draft Statutory Instrument to create new regulated activities for cryptoassets, a near-final step to operationalise the stablecoin framework.

Supervisory rulemaking (FCA). On 28 May 2025, the FCA launched CP25/14, a consultation on rules for stablecoin issuance and cryptoasset custody, which closes 31 July 2025. The proposals include issuer conduct standards, redemption processes, safeguarding and custody rules, and would require fiat-backed issuers to meet a next-business-day (T+1) redemption standard backed by conservative reserve assets.

Systemic perimeter (Bank of England). The BoE has consulted on a regime for systemic payment systems using stablecoins and related service providers, with the goal of ensuring confidence and financial stability if stablecoins come to be used at scale in payments. Debate continues around prudential requirements and systemic guardrails.

What this means for NGOs.

The regime is not fully live yet: the direction of travel is clear (authorisation of fiat-backed issuers, redemption at par, safeguarding and custody requirements), but final FCA and BoE rules are still pending. UK-funded projects should therefore be treated conservatively until the rulebook is in force.

Practical stance for proposals:

Prefer MiCA-regulated E-Money Tokens (e.g., EURC/USDC via EU-authorised entities) when interacting with UK donors until UK authorisations exist.
Classify transfers by liquidity and restriction, following ECHO’s framework: claim “cash” only if par-value redemption and unrestricted use are guaranteed; otherwise treat them as “voucher.”
Explicitly reference alignment with the emerging UK regime, issuance, custody, safeguarding, and T+1 redemption, and commit to updating approaches once FCA and BoE rules are finalised.

Note: The UK regime may diverge in some respects from the EU, particularly around overseas issuers and systemic risk controls. For humanitarian programmes, anchor decisions in three essentials: par-value liquidity, issuer authorisation, and unrestricted use, and document how those conditions are met in the delivery context.

Conclusion: From Question to Clarity
At the Humanitarian Payments Council in Berlin, the sector revisited a question that has lingered for years: are stablecoins money, and can they be used in humanitarian assistance? For a long time, answers were fragmented. Today, thanks to MiCA’s legal framework and ECHO’s CVA policy, the picture is clearer.

MiCA recognises E-Money Tokens as e-money—fully backed, redeemable at par, and legally enforceable. ECHO defines humanitarian assistance through the lens of liquidity and restriction: cash when people have full choice, vouchers when their use is constrained. The liquidity test is a simple but decisive tool: unrestricted equals cash; restricted equals voucher.

This mapping shows that stablecoins are not a new modality. They fit within categories the sector already knows. For NGOs and donors, that matters. It gives regulatory legitimacy, operational clarity, and a common language. Stablecoins can now be piloted and scaled without reinventing humanitarian definitions or creating confusion in donor reporting.

The real challenge is no longer definitional but operational. How well do stablecoins perform in practice? Do they reduce costs, accelerate delivery, preserve donor value, and maintain compliance? And just as importantly: do they feel like real cash in the hands of people we serve?

For now, the takeaway is simple. Stablecoins are rails, not a new form of aid. In humanitarian terms, they are either cash or vouchers, and the measure of success will be whether they uphold the principles that define good assistance: dignity, liquidity, and choice.