Global stablecoin regulation accelerates: China (Hong Kong), the United States and Europe compete for new heights in digital finance

Against the backdrop of the rapid development of global financial technology, stablecoins, as an important bridge connecting traditional finance and digital assets, are gradually becoming the focus of supervision in various countries. On May 21, 2025, shortly after the US Senate passed the Stablecoin Innovation Guidance and Establishment Act (GENIUS Act) two days ago, the Legislative Council of the Hong Kong Special Administrative Region also formally passed the Stablecoin Bill. The bill proposes to establish a licensing system for fiat stablecoins in Hong Kong, aiming to improve the regulatory framework for local virtual asset activities and demonstrate Hong Kong's determination to seize the initiative in the global stablecoin regulatory competition.

Hong Kong Special Administrative Region: Building a robust regulatory framework for stablecoins

The Hong Kong Monetary Authority (HKMA) will be responsible for regulating virtual assets with financial attributes, including stablecoins. According to the new regulations, any entity that issues fiat stablecoins in Hong Kong must apply for and hold a license issued by the Monetary Authority. Licensees must meet a series of requirements, including reserve asset management, redemption mechanisms, anti-money laundering (AML) measures, risk management, information disclosure, and audit systems. In addition, the issuer must have a physical company in Hong Kong and have a minimum paid-up share capital of HK$25 million. The regulations also provide for a 6-month transition period, allowing existing issuers to continue operating under certain conditions.

United States: Promote stablecoin legislation at the federal level

On May 19, 2025, the U.S. Senate passed the GENIUS Act, the first comprehensive federal regulatory bill for stablecoins in U.S. history. The bill requires stablecoin issuers to hold asset reserves equivalent to the stablecoins they issue, ensure that the funds of coin holders are repaid first in bankruptcy, and comply with anti-money laundering (AML) and counter-terrorism sanctions (CFT) regulations. According to Standard Chartered Bank's forecast, the passage of the bill may lead to a nearly tenfold increase in the supply of stablecoins to approximately US$2 trillion in the next four years.

EU: MiCA framework promotes the development of euro stablecoins

The EU officially implemented the Crypto Asset Market Regulatory Framework (MiCA) at the end of 2024, providing a detailed legal framework for the issuance and trading of stablecoins. Although the euro occupies an important position in global foreign exchange reserves and trade, its share in the stablecoin market is still low. However, with the implementation of MiCA, the transaction volume of euro-backed stablecoins has increased significantly, with monthly transaction volume approaching 800 million euros in November 2024. Among them, stablecoins such as Banking Circle's $EURI, Circle's $EURC and Societe Generale's $EURCV are active in the market, together accounting for 91% of the euro-backed stablecoin market share.

Global Stablecoin Regulatory Trends and Outlook

The rapid development of stablecoins has prompted regulators in various countries to step up the formulation of relevant regulations to ensure financial stability and consumer protection. The positive measures taken by China (Hong Kong), the United States and the European Union in the regulation of stablecoins will not only help regulate the market order, but also win greater voice for their countries in the global fintech field. With the gradual improvement of the regulatory framework, stablecoins are expected to play a more important role in the global financial system and promote the healthy development of the digital economy.