When the 2026 law regulating virtual asset business was published in the Official Gazette on May 28, much of the commentary focused on what it bans: individuals cannot trade as a business, virtual assets are not legal tender, and virtual assets cannot be used as a direct means of payment unless the National Bank of Rwanda authorises it.

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Less noticed, but arguably more consequential, is what the law quietly enables for the people who move money for a living.

For payment operators, the headline is settlement speed. Traditional rails still settle on a delay — a day or two domestically, often several days or even weeks across borders once correspondent banks, cut-off times and weekends are factored in. The Virtual Assets Law recognises the issuance and trading of reserve-backed stablecoins and lists the clearing and settlement of virtual asset transactions as a licensable service. Properly regulated, a stablecoin settles in minutes, around the clock, including weekends and public holidays. For a remittance company or a merchant aggregator, compressing settlement from T+2 to near-real-time frees up working capital, shrinks counterparty risk and releases the float that currently sits idle in the system. Handled right, that is not a marginal upgrade; it is a different operating model.

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That model, though, runs through two separate gates rather than one.

Operating a platform that clears and settles virtual asset transactions is a service the Capital Market Authority licenses. Using a stablecoin to actually discharge a payment obligation is a distinct question, because the law provides that virtual assets are not to be used directly as a means of payment for goods, services, debts or any other financial obligation unless the National Bank of Rwanda authorises it. A provider that settles its own obligations in stablecoins could therefore need the central bank's sign-off on top of a CMA licence. Whether stablecoin settlement clears both gates, and on what terms, is exactly the kind of detail the primary law leaves to the regulators — and this analysis will be revisited once the implementing instruments are published.

Crucially, the Virtual Assets Law does not trade speed for control. It goes to considerable lengths on knowing the customer. It imports the FATF "travel rule": the sending provider must obtain, hold and securely transmit accurate originator and beneficiary information with every qualifying transfer, and make it available to regulators on request. Providers must run transaction-tracing tools that screen incoming and outgoing transactions and wallet addresses, alongside strict data-protection and record-keeping duties. Suspicious transactions — including mere attempts — must be reported regardless of value. In short, a faster pipe is permitted only if it is also a cleaner, fully auditable one.

There is a caveat worth stating plainly. The law is in force, but it is not yet operational. It sets the principles and hands the detail to the regulators. Capital Market Authority, as lead regulator working alongside the National Bank of Rwanda, is still drafting the secondary regulations that will define licensing criteria, minimum capital, liquidity ratios and the reserve and audit rules for stablecoins. Until those instruments land, no provider can actually obtain a licence. The starting gun has been fired; the track is still being painted.

Rwanda is reading the global moment correctly. The stablecoin market has pushed past 320 billion dollars, with industry estimates putting annual settlement volumes in the tens of trillions. The United States has passed its GENIUS Act, the European Union's MiCA regime is fully live, and Hong Kong, Singapore and Japan are licensing issuers. Visa and Mastercard already settle on-chain.

By choosing to license rather than ignore, Rwanda positions itself to capture the upside – faster settlement, lower costs, a credible compliance story — while the momentum, which cannot be stopped, keeps building.

The writer is Senior Lead Counsel at PawaPay, a pan-African payments company operating across 20 countries, where he advises on all aspects of commercial law.