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The definition of “electronic money” under Electronic Money Regulations 2011 (EMRs) will be extended to include fiat-linked stablecoins. As a result, holders of such stablecoins will be given a statutory right to redeem their coins on demand and at par value — as is currently the case for holders of electronic money (e.g., prepaid card or electronic wallet account holders). However, the proposals recognize that the holder of a stablecoin may not always have a relationship with the issuer. The holder’s relationship may instead be with a third party such as an exchange or wallet provider.
Accordingly, the UK government considers that holders should generally be able to make a claim against either the issuer or the customer-facing entity as appropriate. The legal requirement to allow the redemption of stablecoin on demand and at par value will remain with the issuer, but the issuer may not always be required to fulfill such requests directly. However, the Consultation Response notes that a direct obligation on the issuer may be imposed where the stablecoin carries systemic risks and direct redemption is necessary to address financial stability risks (see further below).
From UK to Regulate Fiat-Linked Stablecoins – Lexology:
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