On August 1, 2025, Hong Kong once again made a significant move in the global fintech landscape. The highly anticipated stablecoin issuer licensing system under the Anti-Money Laundering and Counter-Terrorist Financing (Amendment) Ordinance officially took effect today. This not only marks a new and more refined stage in Hong Kong's regulatory framework for digital assets but is also seen as a key step in consolidating and reshaping its ambition as a "global Web3 center."
However, behind this race to attract global capital and innovation, a more strategically imaginative question arises: although the current framework mainly focuses on stablecoins pegged to mainstream fiat currencies like the Hong Kong dollar or the US dollar, does it also quietly open a "window of opportunity" for the internationalization of the RMB?
The cornerstone of the system
The core of the new system is that the Hong Kong Monetary Authority (HKMA) acts as the sole regulatory authority, implementing mandatory licensing management for all entities wishing to issue or promote "fiat-referenced stablecoins" to retail investors in Hong Kong.
According to regulations, issuers applying for a license must meet a series of stringent compliance requirements, which cover almost all core aspects of stablecoin operations:
Full reserve assets: Issuers must always hold high-quality and highly liquid reserve assets equal to the total amount of stablecoins they have issued to ensure users can redeem at face value at any time.
Fund segregation: Users' funds must be strictly separated from the issuer's own funds to prevent misappropriation risks.
Operator's "fit and proper" test: Conduct rigorous background and qualification checks on the company's management and key controllers.
Anti-money laundering and counter-terrorist financing (AML/CFT): Establish and implement sound AML/CFT protocols.
Information disclosure: Clear and transparent information must be provided to the public, including the composition of reserve assets and regular audit reports.
It is worth noting that the system has set a high entry threshold. Issuers must have at least HKD 25 million in paid-up capital, a regulation that clearly favors large institutions with strong financial resources, aiming to screen out potential high-risk participants from the outset and ensure market stability and credibility.
Compared to the recently passed GENIUS Act in the US, Hong Kong's system demonstrates its unique advantages. Hong Kong's single regulatory authority (HKMA) model simplifies processes, while the US is complicated by the dual regulatory system of federal and state governments. Additionally, Hong Kong's framework offers flexibility for "multi-currency," providing a broader stage for stablecoin projects with global aspirations.
Local "cold" and cross-border "hot"
Despite the system being in place, stablecoins still face significant challenges in becoming widely adopted in Hong Kong's local consumption scenarios. The consumer payment market in Hong Kong is extremely saturated, covering almost all online and offline scenarios, from traditional Visa and Mastercard to ubiquitous Octopus cards, and to Alipay and WeChat Pay from mainland China. Therefore, analysts generally believe that stablecoins will find it difficult to act as an independent payment tool and achieve breakthroughs in Hong Kong's retail market in the short term.
However, the "coldness" of the local market contrasts sharply with the "heat" of cross-border applications. Hong Kong's unique position as a global trade and financial hub makes it an ideal testing ground for stablecoins to realize their core advantages (high efficiency and low-cost cross-border payments).
Andy K.T. Lau, a partner at David Cameron Law Office, noted that he has observed a shift in client interest in stablecoins from pure speculative trading to exploring their potential as online and offline payment channels. Edwin Cheung, CEO of Gate Dubai, also shared a vivid case: a travel company is considering using stablecoins to solve the problem of collecting payments from hotels and partners around the world. Under the traditional banking system, this process can sometimes take up to thirty days, and in certain countries (such as Argentina and Brazil), smooth banking channels are lacking.
What is more striking is the "great enthusiasm" shown by enterprises from mainland China for Hong Kong's stablecoin system. Although stablecoins are banned in mainland China, e-commerce giants like JD.com and Alipay have confirmed they are exploring the possibility of applying stablecoins to their international business. This clearly indicates that Hong Kong's stablecoin system is being seen as a potential solution for Chinese companies to go global and handle complex cross-border fund flows.
Paving the way for RMB internationalization?
This brings us to the most meaningful part of the entire event. Although current discussions and the first batch of applicants may mainly focus on stablecoins pegged to the Hong Kong dollar or the US dollar, the carefully designed "fiat-referenced" and "multi-currency" framework by the Hong Kong Monetary Authority legally reserves space for the future introduction of offshore RMB (CNH) stablecoins regulated by Hong Kong.
The strategic significance of this move is extremely profound. For a long time, the internationalization of the RMB has faced challenges such as capital account controls and exchange rate fluctuations. As the world's largest offshore RMB center, Hong Kong can provide a perfect "firewall" and "testing ground" for China.
A stablecoin issued in Hong Kong, fully compliant with international anti-money laundering standards, and 100% backed by transparent offshore RMB assets (for example, to be called "CNHC"), would have several potential significant advantages:
Bypassing traditional clearing systems: In international trade settlements, especially for countries along the "Belt and Road" initiative, using CNH stablecoins can bypass the USD-dominated SWIFT system, reducing transaction costs and time while decreasing reliance on a single currency system.
Market-driven internationalization path: Unlike the central bank-driven digital RMB (e-CNY), which mainly focuses on domestic retail payments, a CNH stablecoin issued and promoted by market entities is more likely to be accepted by global markets and users, thus enhancing the usage and reserve status of the RMB globally in a "bottom-up" manner.
Controlled risk innovation experiments: All transactions and innovations occur within Hong Kong's separate customs area and legal system, allowing any potential financial risks to be effectively isolated without directly impacting the financial stability of mainland China.
Summary
The official launch of Hong Kong's stablecoin licensing system is by no means just an industry regulatory policy. It is Hong Kong's declaration of ambition to transform from a "follower" to a "rule-maker" in the global Web3 competition. In the short term, its impact will mainly be reflected in the B2B and cross-border trade payment sectors, providing new digital solutions to address the pain points of traditional finance.
However, from a longer-term perspective, the true value of this system may lie in the realistic path and compliance framework it provides for a bolder financial concept—the digital internationalization of the RMB. Although this is not its current explicit official goal, Hong Kong has undoubtedly set the stage for future potential stablecoins backed by the RMB. The world will closely watch how Hong Kong will leverage this unique "trump card" to play a key bridging and hub role in the future evolution of the global monetary system.