New Developments in Stablecoin Regulation: Accelerated Legislation in the US and Hong Kong, Reshaping the Global Financial Landscape

Recently, the U.S. Senate and the Hong Kong Legislative Council have almost simultaneously advanced legislation on stablecoin regulation. The U.S. overwhelmingly passed the procedural motion for the GENIUS Act, clearing the way for the first federal stablecoin bill. Meanwhile, Hong Kong passed the third reading of the Stablecoin Bill, becoming the first jurisdiction in the Asia-Pacific region to establish a stablecoin licensing system. This high degree of alignment in legislative timing between the East and West is not merely a coincidence, but rather reflects a strategic competition for future financial discourse power.

The stablecoin market has enormous potential

The current global market value of stablecoins has approached $250 billion, growing more than 22 times in the past 5 years. From the beginning of 2025 to the present, on-chain transaction volume has surpassed $3.7 trillion, with the annual total expected to approach $10 trillion. Dollar-based stablecoins are widely used for trading and remittances in emerging markets, with some regions even exceeding traditional payment systems in scale.

According to the calculation model of professional institutions, combined with current regulatory signals and institutional funding attitudes, in an optimistic scenario where the global compliance framework is gradually improving and institutions and individuals are widely adopting, it is expected that by 2030:

• The global stablecoin market supply will reach 3 trillion dollars.
• The monthly on-chain transaction volume will reach $9 trillion.
• The total annual trading volume may exceed 1 trillion dollars.

This means that stablecoins will not only stand alongside traditional electronic payment systems but will also occupy a structural foundational position in the global clearing network. In terms of market capitalization, stablecoins are expected to become the "fourth category of base monetary assets" after government bonds, cash, and bank deposits, becoming an important medium for digital payments and asset circulation.

It is worth noting that the reserve structure of stablecoins will also have a significant impact on the macro economy. Currently, stablecoins have absorbed about 3% of the upcoming short-term U.S. Treasury bonds, ranking 19th among overseas U.S. Treasury bond holders. Considering that the new legislation requires 100% of reserves to be held in highly liquid U.S. dollar assets, if estimated with a 50% allocation ratio, a market value of $3 trillion would correspond to at least $1.5 trillion in short-term U.S. Treasury bond demand. This scale is approaching the current U.S. Treasury holdings of major overseas sovereign buyers such as China or Japan, and stablecoins are expected to become one of the important creditors of the U.S. Treasury.

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

Although the United States and Hong Kong have differences in legislative paths and certain details, they have reached a high level of consensus on basic principles such as "fiat currency anchoring, full reserves, and licensed issuance."

The GENIUS Act mainly targets "payment stablecoins", which are stablecoins pegged to fiat currencies, committed to a 1:1 redeemability, and do not carry interest income, emphasizing their non-securities nature. Hong Kong, on the other hand, has not yet restricted interest income and pegging structure, as long as the 1:1 sufficient peg is ensured, leaving room for future innovation.

In terms of reserve requirements, both the US and Hong Kong require sufficient anchoring of high liquidity assets, but the US legislation clearly specifies the types of eligible reserve assets, including short-term government bonds, cash, and repurchase agreements, and requires monthly audits. Hong Kong also requires audits and segregated custody, but its restrictions on the types of reserve assets are relatively loose.

In terms of institutional framework, the United States adopts a "federal-state" dual-track system, providing multiple pathways for stablecoin issuance. In Hong Kong, the Monetary Authority issues licenses uniformly and requires that regardless of whether the issuer is based in Hong Kong, as long as it is pegged to the Hong Kong dollar or actively provides services to the Hong Kong public, it must apply for a license.

For foreign issuers, the United States clearly prohibits the circulation of unlicensed overseas stablecoins 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 different demands for stablecoin positioning in the two regions. The United States focuses on maintaining the dominance of the US dollar and meeting fiscal needs, promoting stablecoins as an extension of on-chain US dollars; Hong Kong, on the other hand, hopes to attract global Web3 projects while ensuring 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 provide the payment and settlement foundation for the large-scale adoption of Web3. In the decentralized finance ( DeFi ) sector, compliant issued stablecoins will become the clearing core of "compliant DeFi," with protocols embedding more KYC, AML, and asset identification modules, and decentralized finance is expected to evolve into a "verifiable on-chain financial network."

In the Web3 payment system, stablecoins will shift from being a "transaction intermediary" to a true "payment channel". Several payment technology companies have started to integrate stablecoins into merchant settlement processes, and Web3 wallets are expanding various micropayment scenarios with stablecoins as the default payment asset. On-chain payments are transitioning from "transfer tools within the crypto circle" to "enterprise-level financial interfaces", and compliance is a necessary prerequisite for this transformation.

A deeper change lies in the reshaping of the global clearing structure. Stablecoins, anchored to fiat currency at a 1:1 ratio, bridge the connection between local currency and on-chain assets, while not relying on traditional banking 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 central hub of capital circulation.

Regulatory compliant stablecoins provide critical infrastructure support for Web3. They are both institutionally recognized trading assets and possess programmability for on-chain circulation; they are digital mirrors of fiat currency and can be directly applied to DeFi protocols and NFT transactions. With the support of compliant stablecoins, from physical asset transactions to on-chain salary payments, from cross-border settlement to Web3 payment interfaces, stablecoins are expected to become the infrastructure asset that drives the large-scale adoption of on-chain economies.