Both the EU and Hong Kong are actively laying out regulatory frameworks for cryptocurrencies and digital assets, but their legislative processes and focuses differ. The EU is building a strict and unified regulatory system through a series of new regulations, while Hong Kong aims to create a safe and innovative ecosystem for digital assets.#香港稳定币新规
EU (European Union) VS Hong Kong
Core Legislation/Policy
MiCA (Markets in Crypto-Assets Regulation): Comprehensive Regulatory Framework
DAC8: Automatic Exchange of Tax Information Rules
Funds Transfer Ordinance: Expanding the 'Travel Rule' to cryptocurrencies
(Hong Kong Digital Asset Development Policy Declaration 2.0): Overall Development Strategy - Stablecoin Licensing System: Specialized regulation for stablecoins
Core Concept: Establish a strict and unified cross-member state regulatory system aimed at preventing financial crime, tax evasion, and protecting investors. Build a 'trustworthy and innovation-focused' ecosystem that promotes financial innovation and the development of the tokenized economy while ensuring investor protection and risk management.
Regulatory Focus - Comprehensive Compliance: Mandatory reporting obligations, due diligence, and data sharing. - Market Uniformity: Through the 'passport' system, a national license can be used throughout the EU. - Privacy Challenges: Stricter information disclosure and tracking rules put pressure on user privacy. - Precise Regulation: Establishing a unified regulatory framework for exchanges, custodians, and stablecoin issuers. - Product Innovation: Actively promoting the tokenization of real-world assets (RWA) such as government bonds and ETFs. - Orderly Opening: High thresholds for stablecoin license issuance, emphasizing cautious advancement.
In addition to the aforementioned framework differences, the different regulatory pathways of the two regions are also reflected in some specific details and strategic intentions:
· EU: Pursuing institutional unity and security: The EU's regulatory logic leans towards defensiveness and standardization. Its vast market size allows it to set strict rules, with one of the core goals of the MiCA regulations and CASP licenses being to build a secure and transparent internal crypto market. In addition to MiCA, the EU also strengthens tax transparency through the DAC8 directive, requiring digital asset operators to report transaction data, and expands the 'travel rule' to cryptocurrency transfers to enhance tracking of fund flows. These measures, while strengthening regulation, also pose challenges to the privacy characteristics of cryptocurrencies.
· Hong Kong: Focused on innovation and ecosystem building: Hong Kong's pathway shows a more proactive intent to build and connect. The 'LEAP' framework proposed in its policy declaration systematically covers four key areas: law, products, scenarios, and talent. A key initiative is to promote the tokenization of real-world assets (RWA), such as bringing bonds, precious metals, and even carbon credits on-chain, aiming to inject new liquidity into traditional finance and explore new markets. In stablecoin regulation, Hong Kong adopts a high-threshold prudential strategy, expecting to issue only single-digit licenses to ensure a stable market start.
🔭 Future Outlook
Overall, the regulatory pathways of the EU and Hong Kong clearly reflect their respective development strategies:
· The EU is committed to creating a unified regulatory framework and a highly compliant single market for crypto assets.
· Hong Kong strives to become a global hub connecting traditional finance and digital innovation.
Financial-related legislation in Hong Kong generally follows the UK's FCA (Financial Conduct Authority) by approximately six months to a year.