On May 21, 2025, the news of the Hong Kong Legislative Council passing the (Stablecoin Regulation Draft) caused a stir in the trading floors of Wall Street in New York and the City of London. Almost simultaneously, the US Senate passed the first federal stablecoin regulatory bill, the GENIUS Act, while the EU accelerated the compliance process for euro stablecoins under the MiCA framework. This 'stablecoin arms race' spanning China, the US, and Europe is pushing Hong Kong to the core battlefield of the global digital finance map.

1. Regulatory innovation: Hong Kong's ambition of 'multi-currency stablecoins'

Hong Kong Legislative Council member Wu Jiezhuang pointed out that Hong Kong's stablecoin strategy should not be limited to the Hong Kong dollar but should expand to diversified pegged assets like offshore RMB and euros, to build a 'multi-currency stablecoin hub'. This idea is directly reflected in the design of the (Stablecoin Regulation):

1. Flexible anchoring mechanism: Allow the issuance of stablecoins pegged to fiat currencies such as the Hong Kong dollar and offshore RMB, and even support a basket of currency combinations to provide diversified tools for cross-border trade and investment.

2. Sandbox testbed: Three institutions, including Standard Chartered Bank and JD Coin Chain, have tested multi-currency stablecoin models in the regulatory sandbox, among which JD Stablecoin clearly supports a 1:1 peg to the Hong Kong dollar, with plans to expand to RMB scenarios in the future.

3. The world's first bank-issued currency zone: The Hong Kong Monetary Authority has allowed commercial banks to participate in stablecoin issuance for the first time, and the joint venture project between Standard Chartered and Animoca will explore the integration model of 'Hong Kong dollar + Web3 ecosystem', breaking the industry pattern dominated by non-banking institutions.

The underlying logic of this strategy is that Hong Kong is attempting to exchange regulatory inclusiveness for monetary discourse power. When US dollar stablecoins occupy 99% of the global market share, offshore RMB stablecoins may become the 'on-chain channel' for RMB internationalization, and Hong Kong's financial infrastructure and policy flexibility are the key springboard.

2. China-US-Europe regulatory game: Three paths, one battlefield

Global stablecoin regulation has formed three paradigms, and Hong Kong's middle path highlights unique value:

US: Compliance strengthens dollar hegemony

The GENIUS Act includes USDT and USDC in the regulatory framework by mandating reserve transparency and anti-money laundering compliance. The $98.5 billion in US Treasury bonds held by Tether and 80% of Circle's reserves essentially become 'shadow currency funds' in the US short-term debt market. Standard Chartered predicts that this legislation could boost the stablecoin market from $230 billion to $2 trillion within four years, further reinforcing the dollar's 'excessive privilege' in the crypto economy.

Europe: MiCA builds walls to protect euro sovereignty

The EU has forced Tether and other giants to exit the market by limiting the trading volume of non-euro stablecoins (with a daily cap of 200 million euros), while supporting local stablecoins like EURC. Italy's economy minister bluntly stated: 'The threat of dollar stablecoins to European financial sovereignty far exceeds tariffs.' Currently, euro stablecoins compliant with MiCA occupy 91% of the European market share, but their global share is still less than 0.5%.

Hong Kong: Differentiated breakthrough of the hub role

Compared to the strong regulation in the United States and the defensive legislation in Europe, Hong Kong chooses a combination of 'regulatory adaptation + scenario innovation':

Low threshold, high flexibility: The minimum capital requirement of 25 million HKD is far lower than in Europe and the US, with a transition period allowing companies to 'experiment with licenses';

RMB internationalization springboard: Offshore RMB stablecoins can bypass onshore foreign exchange controls, providing a 24-hour settlement channel for cross-border trade. Currently, TrueUSD's TCNH has been trialed on the Tron blockchain;

Web3 ecosystem empowerment: Allow stablecoins to integrate with DeFi, metaverse, and other scenarios; partners like Animoca are developing innovative use cases such as on-chain game payments and NFT dividends.

3. Key variables in the trillion-dollar market: The battle for application scenarios

The regulatory framework is just an entry ticket; the real competition lies in who can seize the core scenarios. The breakthrough point for Hong Kong might be:

1. Cross-border trade finance

Traditional cross-border payment costs up to 6%-8%, taking 2-5 days, while stablecoins can reduce costs to below 1% and achieve real-time settlement;

JD Coin Chain's Hong Kong dollar stablecoin has connected with Southeast Asian e-commerce platforms, and tests show a 70% increase in settlement efficiency.

2. DeFi liquidity hub

Hong Kong licensed exchange HashKey plans to launch offshore RMB stablecoin trading pairs, integrating with protocols like Aave and Compound to build an Asian DeFi liquidity pool;

Currently, USDC occupies 30% of DeFi; if Hong Kong can replicate this model, it may divert $20 billion in funds.

3. Digital asset hedging tools

The HKDR stablecoin from Yuanbi Technology allows users to convert their assets into tokens pegged to the Hong Kong dollar, hedging against cryptocurrency volatility, with a managed scale exceeding 500 million HKD during the testing phase.

4. Concerns and challenges: Compliance costs and geopolitical games

Despite the broad prospects, the Hong Kong model still faces threefold challenges:

Regulatory arbitrage risks: Some projects may exploit Hong Kong's loose framework to issue 'pseudo-compliant' stablecoins, requiring vigilance against a repeat of the 2022 Terra-style collapse;

Geopolitical squeeze: The US may include Hong Kong stablecoins in its financial sanctions against China, restricting their connection to the SWIFT system;

Technological substitution impact: The advancement of digital RMB and digital euro may weaken the intermediary role of multi-currency stablecoins.

Conclusion: Hong Kong's 'stablecoin moment'

While 95% of global stablecoins are still pegged to the US dollar, Hong Kong is trying to break into the trillion-dollar market with a three-pronged strategy of 'regulatory sandbox + multi-currency issuance + scenario innovation'. Legislative Council member Wu Jiezhuang's assertion may be coming true: 'Stablecoins are not just payment tools but also the key to reshaping the global monetary order.'

The outcome of this competition is still unknown, but one thing is certain — whoever can find the best balance between compliance and innovation will grasp the high ground of the next generation of financial infrastructure. Hong Kong has already made its move.

#香港推出稳定币