On August 1, Hong Kong's (Stablecoin Issuance and Reserve Management Ordinance) officially took effect. The Hong Kong Monetary Authority's policy intent is clear: only stablecoins pegged to the Hong Kong Dollar are allowed for issuance, the issuing entities must obtain regulatory licenses, and asset reserves are limited to local currency cash and bonds, with strict auditing and custody processes required. This marks the transition of stablecoins from being purely market-driven products to officially becoming tools for sovereign currency on-chain extension.
Meanwhile, Mainland China is quietly promoting the exploration of stablecoin-related policies. From Hong Kong to the Mainland, stablecoins have moved from a marginal financial innovation topic to the core area of monetary policy and sovereign governance.
Three regulatory pathways for global stablecoins
When stablecoins enter the regulatory language system, they are no longer just technical issues but part of institutional design. The attitudes of different countries and regions towards stablecoins essentially address three issues: the choice of anchoring assets, the attribution of issuance rights, and which clearing logic system to incorporate into the operational system.
Currently, the United States, the European Union, and Hong Kong have a significant impact on the global regulatory direction of stablecoins. They represent three institutional models.
United States: Market-driven, institution-backed
The United States has chosen a market-driven, institution-backed path. After the passage of the GENIUS Act in 2025, stablecoins will be brought under federal regulation. Regulatory authorities do not directly take over issuance but define anchoring methods and backing requirements: allowing the market to issue coins, but they must be pegged to the US dollar, hold compliant reserves, and accept audits from the financial system.
This model establishes a logic of 'front-end openness, back-end support.' As long as it is linked to government bonds or cash, with auditable accounts, it can issue 'dollar interfaces' on-chain. This allows the US dollar to naturally permeate into various corners of Web3, making stablecoins a 'dollar clearing API.'
However, this model also carries risks. Since the power to issue coins is given to enterprises rather than the central bank, if issues such as reserve failures, delayed disclosures, or regulatory gaps across states arise, stablecoins will no longer be pegged to the US dollar but to trust itself.
European Union: Built-in regulation, authority contraction
The European Union has chosen a path of built-in regulation and authority contraction. MiCA places stablecoins under strict regulation. When the circulation scale reaches a certain standard, stablecoins will be classified as 'significant tokens' and must accept intervention from higher financial institutions like the European Central Bank.
This is a typical 'permit-regulate' structure: allowing existence but restricting expansion. The European Central Bank and ESMA have repeatedly expressed concerns about the widespread use of dollar-pegged stablecoins in the Eurozone, fearing it may erode the Euro's monetary sovereignty in the region. MiCA's strong regulatory pathway for stablecoins can be seen as an institutional safeguard.
However, high-intensity regulation may also limit the use cases of stablecoins in the EU, raise issuance costs, and hinder market vitality, making it difficult to support the development of business models centered on stablecoins within the EU.
Hong Kong: Pre-licensing, closed scenarios
Hong Kong has chosen a pre-licensing, closed scenario path. From the beginning, Hong Kong's regulation has 'preset boundaries': only stablecoins pegged to the Hong Kong Dollar are allowed to apply for issuance, prohibiting those pegged to other currencies, multi-currencies, commodities, or using algorithms. Issuers must be registered in Hong Kong, obtain a Stored Value Facility (SVF) license, and may only circulate in locally approved payment scenarios.
This institutional design reflects the threefold intentions of Hong Kong regulators:
Clarification of sovereignty on anchored currencies, only recognizing the Hong Kong Dollar as a stable anchor;
Licensing of issuance qualifications, incorporating stablecoins into the existing financial regulatory framework using the SVF framework;
Closure of use cases, allowing only small-scale pilots in specific payment ecosystems.
This essentially represents a governance model of 'embedded regulation within financial instruments', emphasizing locking issuance and use within a controllable space from the start, ensuring technical validation and risk control of on-chain payments before gradually assessing the path to relaxation.
Possible pathways for RMB stablecoin
As stablecoins enter China's policy agenda, discussions regarding the 'boundaries of currency digitization' are gradually unfolding. Based on publicly available suggestions and policy contexts, the possible issuance structure for the RMB stablecoin is as follows:
The central bank does not issue coins directly but can establish special purpose institutions led by state-owned banks or policy financial institutions for issuance;
The anchoring assets for stablecoins may choose policy financial instruments such as central bank bills, medium-term lending facilities, or part of foreign exchange reserves;
The custody mechanism tends to favor a dual-layer system of on-chain + bank accounts, with asset custody performed by state-owned banks or their subsidiaries;
Pilot implementation pathways may prioritize Hong Kong, conducting licensing applications and cross-border usage tests within the HKMA DTSP framework;
In terms of scenarios, priority will be given to serving cross-border payments, enterprise clearing and settlement, public chain RWA projects, and other B-end demands.
This pathway design essentially promotes the on-chain extension of the RMB and the reconstruction of offshore circulation structures in a regulatory, auditable, and traceable institutional environment. It does not aim to challenge USDT but rather to carve out a 'policy-controllable on-chain payment track', providing institutional tools for the future internationalization of the RMB and the circulation of on-chain assets.
Opportunities for Web3 entrepreneurs
If the RMB stablecoin is implemented, it will be a public infrastructure led by the state or state-owned financial systems. For Web3 entrepreneurs, a more practical approach is to view the RMB stablecoin as a callable system variable and build viable business models around it. Potential opportunities include:
Cross-border settlement tools: Developing payment APIs, settlement plugins, fund flow tracking modules, etc., serving emerging market scenarios.
Real asset connection interfaces: Developing splitting packaging, on-chain debt agreements, revenue right mapping tools, etc. within RWA asset portfolios.
Application scenario services: Promoting implementation in B2B cross-border payments, settlement within e-commerce platforms, overseas education, medical tourism, and other scenarios.
Risk Management and Compliance Intermediary: Developing on-chain AML/KYC plugins, built-in auditing mechanisms for smart contracts, automatic reporting systems for fund paths, etc.
Although the RMB stablecoin is still in the policy discussion and research stage, its implementation has been included in the national strategic vision. For Web3 entrepreneurs, the opportunity lies in early layout around payments, settlements, off-chain connectivity, and cross-border circulation. If the stablecoin pathway opens in the future, service-oriented projects that can provide compliant access points will find it easier to gain resources, policies, and user support.