New Wave of Stablecoin Regulation: Reshaping the Global Financial Landscape is Imminent

Recently, the United States and Hong Kong have made significant progress in the regulation of stablecoins. The U.S. Senate successfully passed a procedural motion for the GENIUS Act, paving the way for the first federal stablecoin legislation. At the same time, the Hong Kong Legislative Council passed the Stablecoin Ordinance Bill on its third reading, becoming the first jurisdiction in the Asia-Pacific region to establish a stablecoin licensing system. The nearly simultaneous legislative actions of these two major economies not only reflect the coincidence of the times but also highlight the intense competition for future financial dominance.

The stablecoin market has huge potential

Data shows that the global market capitalization of stablecoins has approached $250 billion, growing more than 22 times compared to five years ago. From the beginning of 2025 to the present, the on-chain transaction volume of stablecoins has exceeded $3.7 trillion, and it is expected to reach $10 trillion for the entire year. The application of USD stablecoins in emerging markets is continuously expanding, with the usage scale in some regions even surpassing that of traditional payment systems.

Industry experts predict that under the optimistic scenario of gradually improving regulatory frameworks and widespread adoption by institutions and individuals, the global stablecoin market supply could reach $3 trillion by 2030, with monthly on-chain transaction volumes expected to reach $9 trillion and annual transaction totals likely to exceed $100 trillion. This means that stablecoins will not only stand alongside traditional electronic payment systems but will also occupy a key position in the global clearing network. In terms of market value scale, stablecoins are expected to become the "fourth category of base currency assets" after government bonds, cash, and bank deposits, serving as an important medium for digital payments and asset circulation.

It is worth noting that the reserve structure of stablecoins may have a significant impact on the macroeconomy. Currently, stablecoin reserves have absorbed about 3% of short-term U.S. Treasury securities set to mature. If estimated at a 50% allocation ratio, a market value of $3 trillion would correspond to at least $1.5 trillion in short-term U.S. Treasury demand. This scale is already approaching the current U.S. Treasury holdings of major foreign sovereign buyers such as China or Japan, making stablecoins likely to become an important creditor to the U.S. Treasury.

Comparison of Regulatory Frameworks Between the US and Hong Kong: Finding Common Ground in Differences

Although there are differences between the United States and Hong Kong in legislative pathways and specific details, there is a high level of consensus on fundamental principles such as "fiat currency anchoring, full reserves, and licensed issuance."

The GENIUS Act primarily targets "payment stablecoins," which are stablecoins that are pegged to fiat currencies such as the US dollar, promise a 1:1 redeemability, and do not carry interest earnings. The Act emphasizes the non-securities nature of stablecoins, aiming to prevent them from evolving into investment-type financial products. In contrast, Hong Kong has not yet restricted interest earnings and pegging structures while ensuring a 1:1 sufficient peg, leaving room for future innovation.

In terms of reserve requirements, both regions require sufficient anchoring of high liquidity assets. The GENIUS Act clearly defines the types of eligible reserve assets, including government bonds, cash, and repurchase agreements, and requires monthly audits. Hong Kong also requires audits and segregated custody, but the restrictions on the types of reserve assets are relatively lenient.

In terms of institutional framework, the GENIUS Act adopts a "federal-state" dual-track system, providing multiple pathways for stablecoin issuance. In Hong Kong, the Monetary Authority issues licenses uniformly and requires all stablecoin issuers targeting the Hong Kong public or pegged to the Hong Kong dollar to apply for a license, regardless of whether they are established in Hong Kong.

Regarding the management of overseas issuers, the GENIUS Act explicitly prohibits unlicensed overseas stablecoins from circulating in the U.S. market and authorizes the Treasury to establish a "Non-Compliant Stablecoin List". Hong Kong, on the other hand, mainly focuses on stablecoins pegged to the Hong Kong dollar and maintains an open attitude towards non-Hong Kong dollar stablecoins.

These institutional differences reflect the varying demands for stablecoin positioning in the two regions. The United States focuses on maintaining the dominance of the dollar and servicing fiscal financing needs, viewing stablecoins as an extension of on-chain dollars; Hong Kong, on the other hand, hopes to attract global Web3 projects while ensuring local financial stability, creating a controlled yet open compliance innovation testing ground in the Asia-Pacific region.

The Impact of Stablecoin Regulation on the Web3 Ecosystem

The implementation of stablecoin regulation will lay the foundation for payment and settlement for the large-scale adoption of Web3. In the DeFi space, compliance-issued stablecoins will become the clearing core of "compliant DeFi," promoting protocols to embed more KYC, AML, and asset identification modules, gradually transforming decentralized finance into an "audit-able on-chain financial network."

In the Web3 payment system, the implementation of stablecoin regulations will blur the boundaries between payment scenarios and asset circulation, allowing stablecoins to truly transform from "transaction intermediaries" to "payment channels." An increasing number of payment technology companies are beginning to incorporate stablecoins into merchant settlement processes, and Web3 wallets are expanding various micropayment scenarios with stablecoins as the default payment asset. On-chain payments are shifting from "transfer tools within the crypto circle" to "enterprise-level financial interfaces," with compliance being the key to this transformation.

Deeper changes are reflected in the restructuring of the global clearing system. Stablecoins, by anchoring fiat currencies at a 1:1 ratio, connect local currencies with on-chain assets while not relying on traditional bank account systems, enabling peer-to-peer clearing. This means that in future scenarios such as cross-border payments, on-chain trade financing, and physical asset dividends, stablecoins may replace traditional banks as the hub of capital circulation.

Compliance stablecoins provide crucial support for the large-scale adoption of Web3: they are both institutionally recognized trading assets and possess programmability for on-chain circulation; they are digital mirrors of fiat currencies and can be directly applied in DeFi protocols and NFT transactions. With the support of compliance stablecoins, everything from physical asset transactions to on-chain salary payments, from cross-border settlement to Web3 payment interfaces, stablecoins will become the infrastructure assets driving the large-scale popularization of on-chain economies, injecting new momentum into the development of the Web3 ecosystem.