I. Global Regulatory Landscape Accelerates Differentiation

  1. Hong Kong (Stablecoin Ordinance) officially takes effect, first batch of licenses in fierce competition
    Starting August 1, the Hong Kong Monetary Authority officially implements the (Stablecoin Ordinance), requiring issuers to meet a paid-in capital of HKD 25 million, 100% high liquidity reserves (cash or government bonds), and strict anti-money laundering measures. Standard Chartered Bank, JD Coin Chain, and Yuan Coin Technology are among the first popular candidates for licenses in the sandbox test, with the first single-digit licenses expected to be issued in early 2026. The Monetary Authority's president, Yu Weiman, emphasizes 'cautious licensing' in the initial phase, requiring applicants to have technical strength and scenario implementation capabilities to avoid excessive market speculation.

  2. United States (GENIUS Act) signed, consolidating dollar hegemony
    U.S. President Trump signed the (GENIUS Act) on July 18, positioning stablecoins as an extension tool for 'on-chain dollars,' mandating 100% reserve in US dollar cash or short-term Treasury bonds, and prohibiting algorithmic stablecoins. Traditional giants like JPMorgan and Visa plan to jointly launch stablecoins, reducing cross-border settlement costs by 90%. The act also allows non-bank institutions to issue stablecoins but requires Federal Reserve review, potentially sparking market competition between banks and tech companies.

  3. The EU MiCA framework fully implemented, strengthening sovereign protection
    The EU (Crypto Asset Market Regulation Act) (MiCA) took effect in May, classifying stablecoins into Electronic Money Tokens (EMT) and Asset-Referenced Tokens (ART), requiring EMTs to have a 1:1 cash reserve, and ARTs to have 30%-60% of reserves held in banks. It also prohibits non-euro stablecoins for everyday goods payments, with additional regulation for daily transaction volumes exceeding 5 million euros, and mandatory suspension of issuance for amounts over 200 million euros.

II. Market Growth Slows, Compliance Dominates the Industry

  • Scale and Structure: In the first half of 2025, the global stablecoin market capitalization surpassed $250 billion, with annual on-chain transaction volumes reaching $35 trillion, exceeding the total of Visa and Mastercard combined. US dollar stablecoins (USDT, USDC) account for over 85%, but the market share of compliant coins (like USDC) continues to rise, while USDT's share has dropped to 62% due to reserve transparency issues.

  • Technical Iteration: Cross-chain Protocol (LayerZero) and RWA (Real World Asset Tokenization) become new growth points, 30% of new issued stablecoins integrate reserves like US Treasury bonds and gold, with annualized returns increasing to 4%-8%.

III. Regional Policy Dynamics and Impacts

  1. Hong Kong: From Crypto Hub to Compliance Center
    The Monetary Authority plans to explore currency internationalization through offshore RMB stablecoins, with institutions like Standard Chartered Bank and Ant International initiating pilot projects for cross-border trade and DeFi scenarios. JD.com’s stablecoin (JDBC) has been launched on the 'JD Global Sale Hong Kong and Macau Station,' allowing users to shop directly with stablecoins.

  2. Mainland: Cautiously Exploring While Achieving Offshore Breakthroughs
    The digital RMB (e-CNY) pilot covers cross-border payments, retail, and other scenarios, with Shanghai and Hainan exploring offshore RMB stablecoins, issuing stablecoins pegged to CNH through state-owned enterprises abroad to serve financing for 'Belt and Road' projects. In July, Shanghai's state-owned assets started a blockchain cross-border payment pilot, aiming to compress supply chain financing cycles from 30 days to a few minutes.

  3. Singapore: Licensing System and Risk Isolation
    Continuing the 2020 (Payment Services Act), requiring stablecoin issuers to apply for licenses and isolate reserve assets. Strengthening anti-money laundering requirements in 2025 to attract institutions like Circle and Paxos to set up Asia-Pacific headquarters, supporting DeFi and cross-border payment scenarios.

IV. The Global Impact of U.S. Stablecoins

  • Impact on Other Countries: The EU accelerates MiCA implementation, while Japan and South Korea plan to issue their own stablecoins; the penetration rate of stablecoins in emerging markets (such as Argentina and Turkey) increases by 15% annually, as residents use them to replace local currency savings, intensifying pressure on sovereign currencies.

  • Reconstruction of Traditional Industries: Cross-border payment fees drop from 6%-8% to 0.1%, JD.com compresses the 30-day billing period to 2 days in Southeast Asia's durian trade using stablecoins. Over 30% of the value locked in DeFi protocols consists of stablecoins, with platforms like Aave integrating offshore RMB stablecoins to build a decentralized lending market in Asia.

V. Expert Opinions and Future Outlook

  • Risk Warning: The Bank for International Settlements points out that stablecoins lack central bank backing, are prone to money laundering, and may weaken monetary sovereignty. Guotai Junan Securities' Guan Tao emphasizes that stablecoins are unlikely to change the trend of a multipolar international monetary system and highlights the risks of 'regulatory arbitrage' and capital outflows.

  • Trend Forecast: The Hong Kong Monetary Authority expects to issue the first batch of licenses in early 2026, while the entry of U.S. banks and tech giants will enhance industry concentration, with the global stablecoin market capitalization expected to reach $3.7 trillion by 2030. On the technical side, cross-chain protocols and AI risk control will be key to compliance and efficiency improvements.


Summary: By 2025, stablecoins have upgraded from crypto asset tools to financial infrastructure, with regulatory compliance and scenario deepening becoming core trends. Hong Kong attracts innovation with open policies, the U.S. consolidates dollar advantages through legislation, the EU focuses on risk isolation, and the mainland cautiously explores offshore pilots. In the future, the global influence of stablecoins will depend on regulatory coordination, technological innovation, and the dynamic balance of sovereign currency competition.#香港稳定币新规